CONCLUSIONS AND RECOMMENDATIONS
6.3 Administration
The major and most pre-eminent flaw of IEM is that it did not prescribe true integration into the project process but allowed the continued existence of a stand-alone process. Departmental restructuring, project procedure restructuring and education of all staff in a new manner of planning and implementing projects was required in order to effectively implement the IEM guidelines.
It might, however, be assumed that Eskom and other agencies in South Africa could have benefited to a greater extent from overseas experience, by pre-empting the failures in administration already experienced elsewhere. The guidelines should have placed a far greater emphasis on the administrative reform necessary to accommodate implementation.
The progress made by Eskom in altering the project process to accommodate environmental input does reflect the fact that past EIAs and the attempted implementation of the IBM guidelines has indeed educated and paved the way for reform.
Acutt (2001) in her present study has realised that administration requires an accountability facilitated by what is now called partnerships. It is evident that legislation alone cannot attain environmental goals approaching sustainable development nor can mere internal 'voluntary' compliance realise these goals. She advocates partnerships between proponents and I&APs which should enable close working relationships which strive for environmentally balanced development (Acutt, 2001).
The lack of 'clear and consistent administration of the IBM guidelines is also related to the status afforded to environmental management in the company. Where it has higher standing equivalent to other corporate priorities, it will not be esily sidelined in response to business pressures. Thus a higher standing needs to be afforded EIAs at all levels from strategic planning to individual projects to implement the IBM guidelines. A transformation in practice and political will, will be evident when, in times of pressure, companies still enable EIAs to be conducted and not discarded in preference of short term cost and time exigencies alone. It is acknowledged that change in administration is evident but that this is a slow process continually threatened to be de-railed in the face of corporate or development priorities.
It ca also be deduced therefore that voluntary assessment such as sectoral Strategic Environmental Assessment (SEA), presently not legislated, will only take place in an environment where corporates are striving to achieve the high ground in environmental management and not merely trying to achieve what is legislated.
Auditing
• largely not done
• if done focused on effects not process
• testing of predictions not conducted
Monitoring
• lack of continuity as often relegated to a project manager or new environmental offi.cer
• not seen as important as prior steps of the EIA
• often conducted at the individual's initiative
• an inordinate amount of time spent monitoring if prior phases of the ErA not adequately attended to
• monitoring was problematic in that it should have stretched well beyond construction/project close-off and was often curtailed
Environmental Management ~Ian
• the EMP was often neglected if time constraints existed
• the EMP was regarded as having lesser importance
• was often a generalistic and superficial document
• few measurables included made auditing impossible
Review
• using the EIR for review was inappropriate
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Policy
policy imbibes IEM guidelines higher regard for external policy such as the !EM guidelines than internal Eskom policy
citing policy did not ensure compliance
IEM in Eskom 1989 - 1997
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Scoping
Administration time and costs poorly allocated staff constraints
skilled staff required education resulted in some improvement over the period
!EM procedure poorly applied company structure limited !EM application
IEM applied according to external pressure
!EM initially not integrated into project procedure
!EM is beneficial to subsequent project stages when applied incorporation into project process subsequently resulted IBM not applied strategically
• need and desirability well presented to I&APs but not known issues and impacts
• involvement of authorities portrays outwards focus, not integration
• educating I&APs in their rights marginal
• had to overcome I&APs apathy by appropriate techniques
• no scoping at a strategic planning level
• adequate scoping benefited future stages of the EIA project
• scoping done in response to external necessity and landowner pressure
• poor consultation leads to mistrust and conflict
• disadvantaged r&APs marginalised and techniques inappropriate
• efficacy of technique important not number of people reached
• window-dressing to meet procedural requirements as opposed to reaching I&APs
• professionals should have been used to advise on scoping
• alternatives were constrained to project alternatives and not strategic alternatives which were discarded without environmental input
• strategic planning allows alternatives and issues to be investigated outside the constraints of projects
• alternatives have to be aggressively evoked
• issues were not adequately and consistently rated
• specific guidelines only actively sought at the behest of the company not due to compliance with procedure
• !EM educated those involved with its implementation and resulted in some reform
Investigation of Issues
• appropriate review benefits the subsequent phases of the project
• cumulative impacts not investigated
• use of specialists minimised
• on occasion the comments of the NPB were ignored but not that of landowners
• going through the motions
• internal review helped educate and get the support of Eskom management
Figure 3: Summary of Key Lessons Learnt
• usually superficial and general
• social impacts not investigated at all
• investigation constrained due to the unknown cost and time implications
• insufficient time in projects
• investigation necessary to dispel emotional bias
• reliance on internal staff inadequate
• poor scoping resulted in poor investigation of issues
• poor investigation led to costly/irreparable environmental damage and exposed Eskom to legal prosecution