Challenges in Environmental Impact Assessments for Wind Energy Projects in South Africa


and update of guidelines often complicates the EIA process for on-going projects, it does ultimately provide the industry with a clearer understanding of each authority’s views and requirements.


Losing Focus on Key Issues and Significant Impacts


The adjudication of bids in the first window of the IPP Procurement Programme involved very intense legal scrutiny of the bid documentation. For the EIA reports, this led to a ‘tick the box’ review approach to ensure legal compliance with all possible legal aspects, rather than an assessment of whether the most significant environmental and social impacts had been adequately addressed for each project. This approach represents a shift away from the philosophy of integrated environmental management promoted by the DEA that places emphasis on using a scoping process to identify the key issues and then focus the assessment on the most significant impacts related to the proposed development. The guideline entitled ‘Overview of Integrated Environmental Management’ states that “The main purpose of scoping is to focus the environmental assessment on a manageable number of important questions. Scoping should also ensure that only significant issues and reasonable alternatives are examined.”3


The


emphasis on ensuring that all legal technicalities have been addressed can lead to less in-depth assessment of the most significant impacts.


Co-ordination of a Multitude of Applications for Environmental Authorisation


With the rapid expansion of the renewable energy industry in South Africa, the number of applications to the DEA for environmental authorisation for renewable energy projects has increased from almost zero to over 100 in the past two to three years. The ability of the DEA to cope with the co-ordination and evaluation of EIAs relies on a well-structured review of the impact assessment reports by the relevant government departments and organs of state, such as the Department of Agriculture, Department of Water Affairs, heritage authorities and the Civil Aviation Authority. Within the DoE


Conducting an environmental screening study reduces the risk of fatal flaws being identified during the Environmental Impact Assessment


IPP Procurement Programme, a letter of ‘consent’ or ‘no objection’, or at least comment, is required from each relevant department or organ of state as part of the bid to be submitted by the developer. Delays by the various authorities in the submission of their reviews of the EIA reports to the national DEA can pose a challenge for IPPs to meet the submission deadlines for the five bidding windows.


The high turnover of government officials is also problematic for the EIA process. Each application is assigned to a case officer within the DEA. There is often a succession of two, or sometimes three, case officers during the one to two years of the EIA process. For the new case officers assigned to the project, it is a challenge to become fully appraised of the on-going project assessment.


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Another challenge arising from the multitude of renewable energy EIAs that need to be assessed by each government department, as well as the lack of human resources, is the lack of a holistic evaluation of the project. Each department only reviews the section of the report pertaining to its mandate and comments accordingly. Furthermore, a lack of human resources within some government departments leads to the departments issuing generic responses without having time or resources to consider the application on its own merits. These generic responses tend to be precautionary and in some instances are blanket statements of opposition to the project.


Ultimately, it is the mandate of the national DEA to review all stakeholder comments in a holistic manner and make a decision on whether or not to grant environmental authorisation to the project applicant. However, generic negative responses from individual state departments are still problematic to the IPP when these comments are considered as part of the bidding application.


Recommendations for Improving the Environmental Impact Assessment Process


The EIA process for renewable energy developments, and in particular wind energy projects, can be improved by conducting an environmental screening study for selected sites prior to the commencement of the EIA process. This screening study should include a site visit, analysis of available data and information, and input from specialists where


In order to evaluate the overall sustainability of a proposed project a more holistic review should be made by relevant government departments.


necessary. The study should include an evaluation of whether, from an environmental and social perspective, there are any ‘fatal flaws’ or ‘show stoppers’ which would influence subsequent more detailed feasibility studies and project engineering design.4


A fatal flaw is typically defined


By doing so, the developer reduces the risk of a fatal flaw being identified during the EIA process that could delay or prevent environmental authorisation from being obtained.


as an impact that could have a ‘no-go’ implication for the project, unless there is opportunity for the project design to avoid/mitigate this impact effectively.5


If a screening study has been conducted and the developer chooses to proceed to the EIA process, the identification of environmental constraints and no-go areas for the whole site during the screening process is used to inform the project layout and design. In order to improve the efficiency of the EIA process, many developers of renewable energy projects in South Africa are conducting environmental screening studies.


Several data sets are currently available in South Africa with online interactive maps and downloadable geographical information system (GIS) shape files such as the Biodiversity GIS (BGIS) and Agricultural GIS (AGIS) websites. These websites offer a large panel of data sets


MODERN ENERGY REVIEW – VOLUME 4 ISSUE 1


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