Reviewing the quality of EIA follow-up reports for platinum mines in South Africa

Abstract

Literature has shown that there is increasing interest in EIA follow-up, accompanied by the development of EIA regulations to provide for monitoring and evaluation of projects during their construction and operational phases. To date, the practice of EIA follow-up has predominantly focused on the biophysical impacts of individual developments at the project level. The evolution of EIA follow-up beyond discrete projects and with a biophysical focus, through to Socioeconomic- and Strategic Environment Assessment (SEA) follow-up, paves the way to think even further about extending the follow-up concept to sustainability assurance. However, the implementation of EIA follow-up seems to be a worldwide challenge in the sense that emphasis is put on follow-up only during the EIA- and project construction phases. It is clear from the literature that the practice of EIA follow-up still leaves much room for improvement. In many jurisdictions, little, if any, follow-up is done, or it is not provided for in a rigorous or structured manner. This raises a need for a more consistent and structured application of EIA follow-up. This study aims to review the quality of EIA follow-up reports for follow-ups conducted during the operational phase post-EIA for platinum mines in South Africa. To achieve this, a Modified International Best Practice Principles for Follow-Up (IBPPFU-M) framework for the review of the quality of EIA follow-up reports in South Africa was developed as part of the study and applied to follow-up reports from selected platinum mines in South Africa. An evaluation criterion was adapted from the well-established Lee and Colley review package developed in the United Kingdom and the IBPPFU-M review package has been adopted from the IBPPFU, which has been modified using the revised 15 International Best Practice Principles (IBPP) of 2021, as well as the National Environmental Management Act (NEMA) Environmental Impact Assessment (EIA) Regulations, as amended. Data was collected based on the three main objectives of the study, which were to develop a framework for reviewing the quality of 25 EIA follow-up reports sampled from South Africa's selected platinum mines, apply the framework to the selected EIA follow-up reports and identify strengths and weaknesses thereof. The study revealed that the EIA follow-up reports prepared in 2020 and 2021 performed better than the reports prepared in 2019. The EIA follow-up reports compiled in 2019 were mainly based on the requirements of the NEMA Regulations, 2014, as amended, and not Record of Decision (ROD), now referred to as Environmental Authorisation (EA) conditions, when compared to the follow-up reports prepared in 2020 and 2021. It appears that formulation of the ROD conditions and clear legislation have implications on the quality of EIA follow-up reports. This has beendepicted through the identification of recorded similarities in a number of strengths and weaknesses which appeared to have been influenced by mandatory requirements. The results discussed in this research are a starting point to improving EIA follow-up in the South African context.