THE BACKGROUND TO THE CASE STUDIES SELECTED
CHAPTER 5 CHAPTER 5 PROJECT ANALYSIS
5.8 Auditing
Adequate monitoring was not enforced and attendant on the individual as opposed to the process. That is monitoring was not encouraged nor enforced resulting in its neglect unless the environmental officer was sufficiently conscientous and realised the merit and importance of this step for the present project as well as future EIAs/EMPs.
An inordinate amount of time had to be spent on monitoring if previous phases of the EIA had not been adequately attended to. Trying to implement project design changes during monitoring once construction had commenced was almost impossible. Issues had to have been pre-empted and mitigation measures prescribed prior to this stage being reached In order for their satisfactory implement. Trying to implement changes to project design once construction had commenced was also highly costly and disruptive. What is evident from monitoring is that the ability and options available to mitigate impacts diminishes drastically as the project progresses. The onus placed on costly and additional rehabilitation measures, often prescribed during the monitoring stage, conversely increases.
The lack of ability of construction contractors to implement the EMP shows the necessity for monitoring, training and interpretation of the EMP which was often lacking.
Although monitoring could continue after construction was complete, if the Eskom environmental officer so desired, recommendations could not be easily implemented as the project was deemed closed and a whole new project would have to be opened to account for any additional costs. This process could take as long as two years. Monitoring at Hector substation alone took four years and then a subsequent two years to implement some recommendations - post construction completion. This shows the necessity and benefits of long term monitoring post construction.
process was not followed. It merely stated that there were no apparent environmental impacts due the substation's operation and no serious environmental consequences had transpired due its construction.
The audit was limited to the site itself. It in no way referenced the EMP drawn up by the consultant for both construction and operational phases, nor whether its recommendations were adhered nor did it comment on their validity. The auditing therefore has not been holistic as it narrowly considered the substation itself in isolation of its numerous lines exiting and entering the substation and entirely neglected to consider the procedural issues as ensconced in the IEM guidelines and Eskom policy (Eskom, 1997).
Ariadne- Venus 400kV line
No audit has been done in accordance to the format prescribed by IEM for Ariadne-Venus 400kV line 2 EIA. The lessons learnt, however, as a result of the EIA, are signifiant and have been presented at conferences both nationally and internationally (Willemse, 1995d).
Hector 4001275kV substation
A subsequent audit of the Hector substation site, similar to the audit for the Ariadne substation, only assessed the immediate confines of the substation and did not consider beyond the Eskom premises (Eskom, 1997). Eskom could face legal charges if prosecuted for the erosion below the premises on neighbouring property.
Ariadne-Bulwer 132kV line
An audit for the Ariadne-Bulwer 132kV line EIA is not applicable as the project did not proceed to the construction phase.
Kokstad-Mount Frere 132kV line
Only the process followed for the Kokstad-Mount Frere 132kV Line EIA was audited by an Eskom person external to the process. General compliance to IEM was adequately achieved. The "process followed and standard of assessment" was commended by the Eskom environmental auditor and
"noted of being of a high standard within Eskom" (Lucas, letter, 1997). The major shortfall which influenced the thoroughness of the Kokstad-Mount Frere 132kV line EIA scoping and investigation
phases was the inadequate time of 4 months compared to the 6 month period requested in which to conduct the EIA. This was confirmed by the Eskom environmental auditor (Lucas, letter, 1997).
Pongola-Vergenoeg 132kV line
The post construction inspection of the Pongola-Vergenoeg 132kV line EIA does not qualify as a full audit. A form of auditing has been conducted by the Eskom environmental officer who was part of the project from its inception until after its construction. This does not meet the requirements of a formal audit which requires that an independent third party conduct the audit. The audit was concluded after the rehabilitation plan for the line was compiled. Its implementation and the efficacy thereof, however, was not auditted. The lessons learnt on the Kokstad-Mount Frere 132kV Line EIA and EMP prevented similar mishaps on the Pongola-Vergenoeg 132kV line EMP.
Hector-Klaarwater 275kV line
For the Hector-Klaarwater 275kV line, Ariadne-Hector 400kV line, Ariadne-Eros 400/132kV line, Mount Frere 132kV substation and for Eros substation EIAs no known audit has been conducted to date.
5.8.1 Trends Associated with Auditing
Auditing was largely not done. This phase of an EIA is commonly not adequately addressed in projects in South Africa as it reveals predominantly long term benefits.
Auditing was often narrowly focused on the immediate confines of the substation after construction was completed and not on the project process which had preceeded the substation's construction including the EIA, EMP and monitoring. Thus auditing did not constitute an audit in terms of the IEM guidelines.
Testing of predictions was not conducted and would have revealed the necessity for greater measureability and predictability for auditing purposes as opposed to general dsecriptions of impacts and mitigatory measures.