THE BACKGROUND TO THE CASE STUDIES SELECTED
CHAPTER 5 CHAPTER 5 PROJECT ANALYSIS
5.9 Performance of the Eskom Implementation of IEM between 1989 and 1997
qualified EIA consultants to help guide, relied on the appointment of surveyors, botanists, zoologists, etc. This is a reflection of the prevailing lack of awareness and importance atributed to this aspect of the business initially. This was despite visiting overseas specialists having advised Eskom to the contrary and highlighted the need for well skilled employees. There is also concern that lessons learnt from past ElAs and past environmental practitioners are not being conveyed to the newly appointed (Burger, 2000a).
Table lO: Estimated % Implementation of Selected Steps of rEM
Policy Administration Adequacy of Scoping Investigation of Issues
C Review Environmental Management Plan
Monitoring Auditing EIA's OVERALL
ADEQUACY
Unacceptable levels o Investigation f' of only approximately 20 % ade .
projects (see Table lO) T quacy were attaIned for five
. wo others were below standard i.e. b elow 50% adequacy. For two, high
standards were achieved and for three acceptable levels of investigation achieved approximating more than 50 % adequacy. Generalisations were often made during investigations and therefore could not justify and dictate changes to project locality and design.
The implementation of the steps of providing an appropriate EMP and monitoring were inconsistent in their implementation and fluctuated widely as apparent in Table 10. This fluctuation was at times dependent on the environmental officer involved as evident for the implementation of these phases for Hector 400/275kV substation and the Pongola-Vergenoeg 132kV line where monitoring was conducted reasonably weil by someone other than the person who had compiled the EMP. Thus the discrepancy between the rating for the EMP and monitoring for these two projects. The implementation of monitoring, on these two projects, at an individual's initiative and discretion, masks the overall lack of attention to monitoring post the project's implementation by Eskom. This is also a common trend globally (Petts, 1999b; Sadler, 1996 in Hill, 2000; Lee and George, 2000). It is also evident that more attention to monitoring had to be paid when previous steps such as the EIA and EMP were deficient in their compilation and implementation.
Obvious in Table 11 was the inadequacy of the techniques employed for and inadequate involvement of the previously disadvantaged communities. There was at times even entire neglect of the communities concerned or an assumption that consultation with the tribal authority and techniques employed were adequate, neither of which was verified.
Certain aspects of scoping, as evident from Table 11, were conducted very well such as the provision of background information and consultation with authorities. The most preeminent authority was the NPB with whom Eskom regularly and frequently engaged and regarded as the key authority in the absence of a statutory body. This may illustrate a trend of focusing outwards and appeasement as opposed to focusing inward and consistently striving to achieve what was prescribed by the IEM guidelines.
Although learning errors were expected, an improvement in the implementation of the IEM guidelines with time, if there was a true commitment to implementating the guidelines, was anticipated. This was especially expected after the controversy, delays experienced and understanding gained from repeating the Ariadne-Venus 400kV line EIA.
Table 12 is derived from Table 10. Table 12 gives a clear indication of steps and projects where an estimated 60% adequacy of implementation of the IEM steps was attained. Sixty percent is considered a reasonable standard if the supposition is to be made, as was widely accepted, that Eskom, not only accepted, but also implemented the IEM guidelines.
Table 11: Stipulations of the rEM Guidelines to be met during Scoping and the Estimated Extent to which they were Attained
Provision Information
Adequate involvement Authorities
Adequate involvement advantaged I&APs Techniques appropriate advantaged I&APs Adequate involvement disadvantaged I&APs Techniques appropriate disadvantaged I&APs Identification & Selection AltelTlatives
Identification of Significant Issues
Dete.·mination of & Compliance to Specific Guidelines
% ADEQUACY OF SCOPING
It is noticeable that four projects stand out clearly in Table 12. The three Distribution projects 6(the Ariadne-Bulwer 132kV line, Kokstad-Mount Frere 132kV line and Mount Frere 132/22kV substation EIAs relied on the report format generated for and experience gained from the Ariadne-Venus 400kV
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line EIA. This was due to the efforts of the environmental officer to gain this information and not due to immediate company instruction. Thus only the Ariadne-Venus 400kV line repeat EIA can be seen to have had full managerial support and had been conducted adequately in its entirety bar auditing. It is surprising to note that the experience gained from the Ariadne- Venus 400k V line EIA was not
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Table 12: Implementation of Selected Steps ofIEM Attaining >60% Adequacy
60-100%
Policy Administration Adequacy of Scoping
Investigation of Issues Review
Environmental Management Plan
Monitoring Auditing EIA's OVERALL
ADEQUACY
automatically conveyed to the subsequent Transmission EIAs for the Ariadne-Hector 400kV line , Hector 4001275kV substation, Ariadne-Eros 4001132kV line or Eros 400/132kV substation projects.
These projects were all conducted concurrently or slightly subsequent to the Ariadne-Venus 400kV
Whereas the Ariadne-Venus 400kV line EIA attained an exceptionally high rating of 79%
implementation (estimated) it is not considered preposterous to expect at least an improvement to 60%
conformance to the IEM guidelines in subsequent EIAs (Table 12). In contradiction to this expectation Table 10 shows averages of 50, 31, 31, 35 and 42 % implementation of the !EM guidelines being attained for projects, post the Ariadne-Venus 400kV line EIA. Even though these averages are subjectively derived, they give an undeniable indication that there was insufficient attention being given to the implementation of the !EM guidelines even post the Ariadne-Venus 400kV line EIA. Thus it is not inappropriate to consider that the implementation of the !EM guidelines took place:
• when other circumstances or reasons dictated their implementation other than the protection of the environment; or
• that the implementation of the guidelines required a major adjustment which Eskom was unable to consistently make in the short term.
Both arguments have credence.
Table 13 shows that the implementation of the !EM guidelines was totally inadequately attempted for some projects. This may be deemed understandable prior to the Ariadne-Venus 400kV line EIA being repeated but less than 40 % attainment of successful implementation thereafter once again illustrates that, as has been discussed in Chapter 5, external factors such as political will and the necessary reform to accommodate and implement the guidelines was a prior necessity. It is clear that auditing was badly neglected in contradiction to a statement made that "environmental impact assessment and management plans will be implemented and audited for all major construction projects" (Eskom, 1993a). Scoping, as being the step upon which subsequent phases of the project depended, was relatively well conducted and more specifically for landowners (Tables 13 and 14).
Overall, the citing of policy was the only IEM step to be commendably implemented in the author's opinion (Tables 12 and 14). However, ascertaining compliance to the !EM guidelines by assessing the citing of policy in the EIR does not necessarily give a true indication of compliance either. Ultimately a better assessment is whether or not policy was complied with or cognisance was taken of it when implementing the EIA. Citing Eskom environmental policy or referencing the Eskom EIA procedure, which was similar to the !EM guidelines, should have resulted in greater compliance to the !EM guidelines. This trend is not noticeable and therefore the citing of policy, even though well done, often amounts to 'lip service'.
Table 13: Selected Steps of IEM where < 40% Estimated Implementation was Attained.
Policy Administration Adequacy of Scoping Investigation of Issues
Review Environmental Management Plan
Monitoring Auditing EIA's OVERALL
ADEQUACY
Table 14, depicting 50% compliance, accentuates the trend prevalent in Table 13 where certain EIAs were conducted more in compliance to the rEM guidelines than others due to various external factors as discussed in Chapter 5. Aspects such as project administration, the investigation of issues and review are highlighted in Table 14 as having been shown less than adequate attention as well.
Table 14: Selected Steps of IEM where < 50% Estimated Implementation was Attained.
Policy Administration Adequacy of Scoping Investigation of Issues
Review Environmental Management Plan
Monitoring Auditing EIA's OVERALL
ADEQUACY
If an estimated average attainment of approximately 60 % may be deemed an attainable point with an indication of improvement with time being indicative of Eskom having adequately attempted implementing the !EM guidelines then it is evident that either Eskom was not comitted to their implementation or they were not implementable in the short term.
In conclusion it was considered irrefutable that the !EM guidelines were accepted and to be implemented by Eskom, however, the implementation thereof was deficient when conducted on a