An assessment of the monitoring aspect of the environmental impact assessment procedure in Cape Town, South Africa

Abstract

This thesis assesses the monitoring aspects of the Environmental Impact Assessment (EIA) procedure in Cape Town, South Africa. EIA is a tool used within sustainable development to identify, predict, evaluate, and mitigate potential impacts of proposed developments. This study argues that for EIAs in South Africa to contribute effectively to sustainable development, they must be underpinned by a holistic “cradle to grave” approach (DEAT, 2004c: 4–10). Currently, this is not the case, as Cashmore et al. (2004) argued that the EIA process is “relatively inefficient at ensuring: impacts were minimized; irreversible impacts were avoided; and sustainable development was facilitated.” These concerns are echoed by Jay et al. (2007) and Devuyst (2000: 68–72). With the establishment of the Environmental Assessment Practitioners Association of South Africa (EAPASA), only registered environmental assessment practitioners (EAPs) are mandated to conduct the EIA process; however, no such mandate exists for post-EIA activities1 . The EIA process is seldom undertaken outside the pre-feasibility or feasibility phase, creating an administrative hurdle for project progression. However, Schmidt et al. (2008) noted that the subsequent engineering design phase often results in EIA-approved designs evolving and developing post-environmental authorization (EA), potentially invalidating or rendering inapplicable many originally predicted environmental impacts. Conversely, design changes may introduce "new" environmental impacts. Upon construction commencement, the responsibility for ensuring adherence and compliance with the environmental management programme (EMPr) and environmental authorization falls to either the environmental control officer (ECO) and/or the environmental auditor. Ironically, the ECO's roles and responsibilities are undefined, while the environmental auditor is merely required to possess environmental auditing experience. Both roles remain unregulated within the broader South African environmental management industry. Consequently, quality control of post-EIA related work remains unchecked, and current post-EIA learnings do not iteratively inform future EIA processes. To assess the monitoring aspects of the post-EIA procedure in South Africa, Phase Two and Phase Three of the proposed Plankenbrug Main Outfall Sewer and Associated Works development in the Western Cape were used as an illustrative case study. A qualitative research design was adopted, supplemented by surveys, focus groups2 , and in-depth face-to face interviews with various industry stakeholders. Primary data collected from interviewees and research participants was augmented with secondary data sourced from various documentary and archival materials. This study revealed that the EIA regime in South Africa is not fully effective due to several procedural shortcomings inherent in the EIA process, which diminish its contribution to achieving the ideals of sustainable development. Finally, the study concludes that without a “cradle to grave” approach, a holistic view of impacts assessed throughout the development lifecycle will not be achieved, hindering effective mitigation.