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ASPECTS OF ENVIRONMENTAL IMPACT ASSESSMENT (EIA) PRACTICE IN THE LIMPOPO PROVINCE - SOUTH AFRICA Luke A Sandham1, M Victor Siphugu2 and Thivhulawi R Tshivhandekano3 Environmental Assessment Research Group, School of Environmental Sciences and Development, North-West University, Potchefstroom, South Africa, 2520 2 Bembani, P O Box 1589, Sunninghill, South Africa, 2157 3 University of Venda, P/Bag X5050, Thohoyandou, 0950, South Africa Correspondence: Luke A Sandham; ggflas@puk.ac.za Abstract Following the introduction of the environmental impact assessment (EIA) regulations under the Environment Conservation Act No. 73 of 1989, hundreds of EIA reports are produced every year in South Africa. However, there is still a dearth of empirical investigation of EIA practice, hence it is difficult to assess the effectiveness of the EIA process in South Africa. Selected aspects of a random sample of EIAs conducted in the Limpopo Province were investigated, focusing on baseline information, specialist studies, duration taken for projects to be authorised and the record of decision (ROD). In general, with the exception of social baseline information, the frequency and quality of baseline information were satisfactory. The quality of specialist studies (although not normally required for the scoping report) was also satisfactory. Duration of projects was satisfactory with authorisation generally within 12 months. Notably, all applications in the sample received a decision at the scoping phase, without any projects requiring a full Environmental Impact Assessment. Judging by the aspects of EIA investigated, EIA practice in the Limpopo Province is generally well compliant to the regulations and guidelines, but capacity and skill in EIA compilation and review needs to be increased. Key words: EIA, activity category, baseline information, specialist studies, record of decision
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1. Introduction Investigations carried out to determine the impacts on the environment of major projects are referred to as Environmental Impact Assessment (EIA). EIA is a planning and management tool for sustainable development, aimed at providing decision-makers with information on the likely consequences of their actions. Thus EIA can be considered as being anticipatory in nature. EIAs define and assess the potential physical, biological, socio-economic and health effects of the proposed project in a manner that allows for a logical and rational decision to be made about the proposed action (Glasson et al., 1995; Wathern, 1988; Wood, 2003). EIA was first developed in the United States of America as a result of the National Environmental Policy Act of 1969 (NEPA). EIA was then introduced in California in 1970, and was later adopted by other Federal States. European countries followed the United States example of enacting legislation that required EIAs to be conducted for all major projects (Barker and Wood, 1999). The Commonwealth of Australia announced its EIA policy in 1972, Canada followed in 1973, and several other countries also established EIA systems around the mid 70s e.g. New Zealand, Columbia, Thailand, France and the Netherlands (Barker and Wood, 1999; Bregman, 1999; Fuggle 1992; Lee, 1995; Muttamara, 1996; Lee and George, 2000; Wood, 2003). However, the practice of environmental impact assessment commenced much later in developing countries (Leu et al., 1997; Lee and George, 2000; Sankoh, 1996). Indeed, until recently in developing countries, developmental projects have frequently taken place without any EIAs (Appiah-Opoku, 2001. In most of Africa, EIAs were conducted mainly by donor and multilateral agencies, until the adoption of EIA legislation from the mid-1980's (Kakonge, 1999; Tarr, 2003). In South Africa, EIA has been practiced on a non-mandatory (voluntary) basis as part of integrated environmental management (IEM) since the mid-1970s (Wood, 1999; Burger 2004). EIA became a legal requirement for a wide range of projects in September 1997 in terms of sections 21, 22 and 26 of the Environmental Conservation Act (ECA) No. 73 of 1989 (South Africa, 1989; 1997). The competent authorities1 for administration of EIA are the nine provincial departments of Environmental Affairs, and for certain projects, usually larger and/or of a transboundary nature, the national Department of Environment and Tourism. The National Environmental Management Act (NEMA) (South Africa, 1998) promulgated after EIA became mandatory - makes provision for EIA, and new regulations under the relevant sections of NEMA were published for comment in June 2004 (South Africa, 2004b) for anticipated promulgation in 2005. Until these are promulgated, EIA continues to function under the current EIA regulations. EIAs for mining activities are required in terms of Section 107(1) of the Mineral and Petroleum Resources Development Act (South Africa, 2004a), but the Department of Minerals and Energy is the competent authority The categories of activities that require EIA in South Africa are listed in the EIA regulations (South Africa, 1997). Furthermore, the EIA regulations provide a detailed description of the EIA process that should be followed (see Figure I), containing all but one of the generic phases of EIA, i.e. screening, scoping, consultation, impact
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The organ of state responsible for issuing a decision on an EIA application 51

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prediction, alternatives, mitigation, review, decision making and appeal, with the exception of post-decision monitoring (Wood, 2003). The scoping report must include a brief description of the project and of how the environment may be affected, a description of environmental issues identified, a description of all alternatives identified, and an appendix containing a description of the public participation process followed, including a list of interested parties and their comments. After considering the scoping report the relevant authority may issue authorization with or without conditions, contained in a record of decision (ROD). In the case where information contained in the scoping report is considered to be insufficient, the relevant authority may request that information in the scoping report be supplemented by a full environmental impact assessment, to be submitted as an Environmental Impact Report (EIR) (South Africa, 1997; Rossouw et al., 2003). It must be noted here that EIA practice in South Africa has evolved to the point where much of the EIA process is included in the scoping report e.g. impact identification and mitigation, environmental management steps and extensive public consultation, in order to short circuit a potentially drawn-out administrative procedure. Consequently, many scoping reports take on the form of a "beefed-up" scoping or a "mini-EIA". The influence of this practice is discussed below. Whilst the EIA regulations provide all the procedural requirements that should be followed while conducting EIAs in South Africa, a largely qualitative picture of EIA practice has emerged from discussions and interviews with government officials, consultants and NGOs (Wood, 1999 & 2003; Rossouw et al., 2003), but apart from some work in the North West Province (Sandham et al., 2002), very little empirical investigation of EIA practice has been done in South Africa. Moreover, in order to assess the effectiveness of the new regulations (South Africa, 2004b), a baseline of EIA practice is essential. This article reports on an empirical investigation of EIA practice in Limpopo Province, focusing on baseline information and specialist studies, the duration of the EIA process and on the record of decision (ROD) in a selected sample of EIA files from the Environmental Authority archives of the Limpopo Province. 2. Study area The files investigated in this study were for projects from a wide range of geographic locations within Limpopo Province, which is situated at the North Eastern corner of the Republic of South Africa, sharing international borders with Botswana to the west and northwest, Zimbabwe to the north and Mozambique to the east. Within South Africa the province shares borders with Gauteng Province to the south, North West Province to the southwest and Mpumalanga Province to the southeast. The province covers an area of 123 910 square kilometres, i.e. 10.2% of the surface area of South Africa. The majority (89%) of Limpopo's population lives in rural areas without adequate water supply and sanitation facilities, as well as inadequate telecommunication facilities and electricity supply. (Office of the Premier of Northern Province, 1998).

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Figure 1. The South African EIA process (after Rossouw et al., 2003)

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3 Materials and methods The Department of Finance, Economic Affairs and Tourism (DFEAT) is the competent authority in the Limpopo Province, and a random sample of 95 EIA files housed in their Polokwane offices was selected for investigation. Several categories of listed activities (i.e. for which EIA is required) including water storage and supply, township development, resort development and storage and handling of hazardous substances had more than 20 completed EIA files. From each of these categories, 60% of all the completed EIA files were randomly selected for the study. The remaining categories of listed activities had fewer (less than 15) completed EIA files, and for these categories all the completed EIA applications were considered for this study. The categories of activity from which the files were selected included: "Canals, Dams, Levees, Weirs and Reservoirs", hereafter referred to as "canal"; "Power lines, electricity stations, etc", hereafter referred to as "power line"; "Township development", hereafter referred to as "township"; "Resort development", hereafter referred to as "resort"; "Handling of hazardous substances", hereafter referred to as "hazardous substance"; "Roads, railways, and airfields", hereafter referred to as "road"; "Change of land use"; "Sewage works", hereafter referred to as "sewage"; "Landfill development", hereafter referred to as "landfill". The number of files in each category is presented in the last row of Table 1. The duration considered for this study was from 1997 (when EIA became mandatory in South Africa) until the end of 2001, and the investigation focused on the following aspects of EIA: 1. frequency and quality of baseline information, 2. frequency and quality of specialist studies, 3. duration of EIA and authority review, and 4. record of decision (ROD). The quality of baseline information (where present) was evaluated on a simple scale in terms of the quantity of information as well as the preciseness of the description of different factors. EIAs with baseline information that was sparse or not clearly presented were considered to have a "poor" quality of baseline information. Reports with a wealth of information that was clearly and logically presented were considered to have "good" quality of baseline information, and intermediates were categorized as "acceptable". The quality of the specialist studies was evaluated in the same way. Duration of projects and authority review was determined by start and end dates. RODs were investigated with particular reference to the stage at which the ROD was issued and conditions of approval. The data sheet that was used to collect data during the investigation appears as Appendix 1 in Siphugu (2003). 4. Results and discussion 4.1 Baseline information Baseline studies describe the physical, biological and social environments before the project is undertaken. This forms an essential part of the EIA as it provides the basis for making a judgement on whether the project will result in significant impacts on 54

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the environment or not. Baseline studies provide the before-project record and the impacts of the project can be determined by means of post-decision monitoring, using the before-project baseline information (Beanlands, 1988; Bregman, 1999; Wathern, 1999; DEAT, 2002). 4.1.1 Frequency of baseline information Most of the projects (96%) that reached the "scoping report" stage contained some form of baseline information (Table 1) including biological, economical, physical and social information. Most of the investigated files (93%) contained biological and physical baseline information, and 82% contained social baseline information. However, economical baseline information was absent in many EIA files - e.g. power lines, sewage and landfill - with a mere 14% occurrence in the sample. Table 1: Frequency of baseline information per activity category
Canal Biological Physical Economical Social Total Projects with B-L. Total sample 14 14 3 12 15 17 Power line 3 3 0 3 3 3 Township 14 13 2 9 14 14 Resort 15 14 1 14 15 15 Hazardous substance 15 16 1 12 16 16 Road 9 10 1 10 10 10 Change of land use 11 11 5 11 11 12 Sewage 4 4 0 4 4 5 Landfill 3 3 0 3 3 3 Total 88 88 13 78 91 95 % 93 93 14 82 96 100

Biological and physical baseline information occurred most frequently. This is most likely due to the ready availability of such information and to the fact that biological and physical aspects of the environment are often combined and considered as biophysical conditions. The flora of South Africa, for example, have been described by Acocks (1988), and it appears that this publication served as the primary source for most biological baseline studies in the sample. Moreover, since it appears that most EIA consultants have a natural sciences background, and that this type of information has a more quantitative nature, it is to be expected that consultants would be more familiar with conducting biological and physical baseline studies. Lastly, the roots of environmental management in ecological issues are still exerting a "green" bias with a resultant emphasis on the biophysical aspects of the environment, often at the cost of human aspects. This is in agreement with the observation of Wathern (1999) that ecological baseline information was most common in EIAs surveyed in the UK. The findings for biophysical and economic baseline information are in broad agreement with those of the North West Province (Sandham, et al. 2002), although the frequency of biophysical baseline is lower in the North West at 60%. The status of economical baseline information is also in general agreement with that of the North West Province (Sandham, et al. 2002), although the frequency of economical baseline information is higher in the North West (30%). This observed paucity of economic baseline information could similarly be ascribed to the natural science bias of most consultants, as well as to the current generally poor association of economic issues with environmental issues. It is important therefore, that EIA consultants either be trained in or include economic skills in their teams. Social baseline frequency is considerably higher in the Limpopo Province than in North West (68% vs. 38%), and this relatively high frequency is encouraging, since, like economical issues, it is often neglected in favour of biophysical information. This is most likely due to the emphasis placed on social issues in the South African

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EIA system, largely as a result of and as an attempt to redress social imbalances of the past (See also specialist studies below). 4.1.2 Quality of baseline information The quality of baseline information per activity category is presented in Table 2 and a comparative summary in Figure II. Similar quality trends are evident i.e. for all four types of baseline information a small fraction (2-14%) is of poor quality, a large proportion is of acceptable quality (77-85%) and the smallest fraction (1-8%) is of good quality. Ironically, it is economic baseline information with the lowest frequency that has the highest percentage of good quality information. However, since the 8% of good quality reports consists of a single case, this high percentage can hardly be regarded as representative. While it is encouraging to note that the majority of the sample contained satisfactory biological, physical and social baseline information, it is nevertheless a matter of concern that 13-14% of the sample had poor quality baseline information, to which must be added the proportion of files that had no baseline information at all. Examples of poor quality of biological baseline information include: a single paragraph describing both plant and animal life in the project area, e.g. some grass species and shrubs were observed in the project area without providing any further details of the grass species and shrubs present in the area. Typically there would also be no indication of the occurrence of any plants or animal species of conservation importance (endangered or threatened species). Clearly, such baseline information cannot be sufficient and therefore decisions based on such inadequate information might not be optimal. Table 2 Quality of baseline data by project category and baseline type
Project category
Baseline type Baseline quality Canal Power line Township Resort Hazardous substance Road Change of land use 1 10 0 11 1 10 0 11 0 4 1 5 0 11 0 11 Sewage Landfill n Total %1 %2

Poor Biological Acceptable Good Total Poor Physical Acceptable Good Total Poor Economic Acceptable Good Total Poor Social Acceptable Good Total
1 2

3 10 1 14 4 9 1 14 1 2 0 3 4 8 0 12

0 3 0 3 0 3 0 3 0 0 0 0 0 3 0 3

3 11 0 14 3 10 0 13 0 2 0 2 1 6 2 9

1 14 0 15 1 13 0 14 1 0 0 1 4 10 0 14

4 11 0 15 3 13 0 16 0 1 0 1 2 10 0 12

0 8 1 9 0 10 0 10 0 1 0 1 0 10 0 10

0 4 0 4 0 4 0 4 0 0 0 0 0 4 0 4

0 3 0 3 0 3 0 3 0 0 0 0 0 3 0 3

12 74 2 88 12 75 1 88 2 10 1 13 11 65 2 78

14 84 2 100 14 85 1 100 15 77 8 100 14 83 3 100

13 78 2 93 13 79 1 93 2 11 1 14 12 68 2 82

Percentage of number of projects containing baseline data Percentage of total sample i.e. 95 cases

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The majority of files contained acceptable quality physical baseline information. It is of concern, however, that files with good quality of physical baseline information comprised less than 5% of all the files investigated. This is one of the areas in the EIA report that needs serious attention if the EIA system in Limpopo Province and South Africa as a whole is to achieve greater effectiveness. The quality of social baseline information was generally satisfactory. However, in a survey of over 100 EIA projects in Limpopo province, Tshivhandekano (2003) has observed a contradictory trend with regards to the consideration of social impacts. He reported that social impacts were largely ignored in the investigated files. This indicates that there appears to be a weak connection between social baseline information and the prediction of social impacts in the EIA system in Limpopo Province. This discrepancy can most likely be attributed on the one hand to the intent in the South African EIA system to address inequalities of the past by insisting on attention being given to social issues, hence high frequency and good quality of social baseline information. On the other hand, social impact assessment is known as a difficult and neglected issue (Vanclay, 1999; Burdge, 2002; Chadwick, 2002). This is another weakness of the EIA system in Limpopo Province that needs further attention. Figure II Quality of baseline information per activity category
120 100

Number and % of files

80 60 40 20 0 Acceptable Acceptable Acceptable Acceptable Total Total Good Good Good Good Total Total Poor Poor Poor Poor

Biological

Physical

Economic

Social

Total of baseline data (n)

% of baseline

% of Sample

4.2 Specialist studies Specialist studies are not required at the scoping phase in the South African EIA system (South Africa, 1997). However, as mentioned above, this is part of the beefed-up scoping approach adopted by many consultants (and often requested by officials) to submit the specialist studies at the scoping phase in order to give additional weight to the scoping report to speed up authorization.

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The numbers of specialist studies contained in EIA files in various listed activity categories are shown in Table 3. For some activity categories i.e. canal, resort, hazardous substance, road and change of land use - more than half of the projects had no specialist studies at all. In all the categories of activity where specialist studies did occur, the majority of EIAs contained between one and three specialist studies. Only in two categories of activity (canal and road) did the EIAs contain four or more specialist studies. Table 3 Frequency and quality of specialist studies
Canal Power line Township Resort Hazardous Change of Road Sewage substance land use Landfill Total Total %1 % of sample2

Frequency of specialist studies per listed activity category 0 1 2 3 4+ Total projects Poor Acceptable Good Total specialist studies
1 2

9 3 4 0 1 17 0 7 1 8

1 1 1 0 0 3 0 2 0 2

3 6 4 1 0 14 0 10 1 11

11 1 2 1 0 15 0 4 0 4

10 3 0 3 0 16 0 6 0 6

6 1 1 1 1 10 0 4 0 4

6 3 2 1 0 12 0 6 0 6

3 1 1 0 0 5 0 2 0 2

0 1 1 1 0 3 0 3 0 3

49 20 16 8 2 95 0 44 2 46

N/A 44 35 17 4 100 0 96 4 100

52 21 17 8 2 100 0 46 2 48

Quality of specialist studies per listed activity category

Percentage of number of projects containing specialist studies, i.e. 46 cases Percentage of total sample i.e. 95 cases

More than half of the sample (52%) did not have any specialist studies at all; similar to over 50% for the North West Province (Sandham et al., 2002). EIAs containing one specialist study formed 21% of the sample, with reports containing two specialist studies making 17% of the sample. Fewer EIAs contained more than two specialist studies with only 8% containing three specialist studies and a meagre 2% contained four or more specialist studies. In actual numbers only two EIAs out of a total of 95 EIAs investigated contained four or more specialist studies. It is encouraging to note that all of the specialist studies (96%) were judged to be of acceptable or good quality (Table 3). Given that experts in their specialized fields conduct these studies, it can be expected that the studies prepared could be of good quality. It cannot however be assumed that they will be of good quality; hence strict review of the reports remains necessary. The types of specialist studies occurring in the sample are shown in Table 4. Table 4 Type of specialist studies per activity category
Canal Biological Archaeolog ical Geological Hydrologic al Social Noise 3 6 2 2 2 0 Power line 0 2 0 0 0 0 Town ship 5 6 6 0 0 0 Resort 1 4 3 0 0 0 Hazardous substance 2 2 6 3 0 0 Road 3 4 1 1 1 1 Change of land use 1 4 4 0 0 0 Sewage 1 1 0 0 0 0 Landfill 1 1 3 2 0 0 Total 17 30 25 8 3 1
1 2

37 65 54 17 4 1

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Traffic Total proj with spec studies. Total proj

1

0 8 17

0 2 3

0 11 14

0 4 15

1 6 16

0 4 10

0 6 12

0 2 5

0 3 3

1 46 95

1 48

Total specialist studies per type 2 Percentage of number of projects containing specialist studies, i.e. 46 cases

Archaeological studies were the most common specialist studies, occurring in 30 (65%) of the total of 46 files that contained specialist studies, followed by geological studies in 25 (54%) of the files, biological studies in 17 (37%) and hydrological studies fourth with 8 (17%) occurrences (Table 4). Social studies were also contained in some EIAs, with noise studies and traffic studies only mentioned in one EIA each. The results are again in line with the findings by Sandham et al. (2002) for the North West Province. Similar to the baseline situation, the predominance of the biophysical specialist studies is most likely due to the fact that many EIA consultants have a natural science background and are therefore more aware of the need for specialist studies in those fields. An interesting anomaly, also observed in the North West province, is the high frequency of archaeological studies. There appears to be no clear reason for this other than it being an outflow of the intent in the South African EIA system (as mentioned above) to address inequalities of the past with a strong emphasis on social issues, and archaeological studies being one of the more accessible forms of social specialist studies. 4.3 Duration of EIA and authority review 4.3.1 Project duration Table 5 shows the time elapsed from receipt of application by the relevant authority until the record of decision (ROD) was issued. Some activity categories did not have any EIA that took less than one month from application until the issuing of the ROD. Several categories had one or two EIAs that were authorized within one month, with only the category, canal, with up to four EIAs that were authorized within a month. Increases were seen in numbers of projects authorized within three months in almost all the categories, with a few increasing to most within 6 months (township and change of land use). The numbers decline for projects that were authorized within 6 12 months, and also projects that took over one year to be authorized. Table 5. Project and review duration.
Duration (months) * <1 1-3 3-6 6-12 > 12 Total projects Canal P 5 6 4 1 1 17 R 6 8 2 1 0 Power line Township P 1 0 1 0 1 3 R 1 2 0 0 0 P 0 2 7 5 0 14 R 0 6 4 3 1 Resort P 1 3 6 4 1 15 R 2 7 4 2 0 Hazardous substance P 2 7 4 3 0 16 R 4 8 4 0 0 Road P 2 2 1 5 0 10 R 3 3 0 4 0 Change of Sewage land use P 0 1 7 2 2 12 R 1 2 8 0 1 P 1 2 0 2 0 5 R 2 2 1 0 0 Landfill P 0 0 1 0 2 3 R 0 1 0 1 1 Total P 12 23 31 22 7 95 R 19 39 23 11 3 % of sample P 13 24 33 23 7 100 R 20 41 24 12 3

P = Duration of project from application to record of decision; R = duration of authority review of scoping report

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Figure III Duration of projects and authority review

45 40 Number of projects 35 30 25 20 15 10 5 0 Less 1mth 1-3 mth 3-6 mth 6-12 mth Over 12 mth Project duration Duration of authority review

Figure III shows the average time frames within which projects were authorized. The number of projects authorized within one month comprised 13% of the sample. The numbers increased as the duration increased, with projects authorized within one to three months making about 24% of the sample; 33% authorized within three to six months and 23% authorized within 6 to 12 months, whereas only about 7% of all the projects took longer than 12 months to be authorized. These periods are similar to those observed in the North West Province of 5.5 months (Sandham et al., 2002), but considerably shorter than the average time (10 months) in Norway between application and authorization by the decision-making authorities (Holm-Hansen, 1997). This could be attributed to fact EIAs in Norway are more detailed than they are in South Africa. Glasson et al. (1995) reported that in the USA EIA reports are generally around 150 pages or slightly less, whereas in the UK some EIA reports exceed 150 pages in length. The average length of EIA reports investigated in Limpopo Province is seldom more than 50 pages, considerably shorter than the average length of EIAs mentioned above, hence the shorter duration. 4.3.2 Authority review duration Data on the time taken by the authority to review submitted scoping reports are presented in Table 5 and Figure III. In 19% of cases the authority review period was less than one month. The majority of the projects (41%) were reviewed within one to three months. In 25% of all the projects the authorities took between three and six months to review the submitted scoping reports, whereas review periods of between 6 and 12 months were observed in 12% of the projects. Only 3% of the total number of projects had their scoping reports reviewed over a period exceeding 12 months. Figure III shows the almost normal distribution of EIA duration around the peak of 36 months, whereas the duration of authority review quite correctly is skewed to the shorter duration of 1-3 months, which is to be expected since authority review is only one of the components of the duration of an EIA. In the majority of projects (60%), authority review was finalized within three months after the submission of the scoping report. In a few projects authority review was, in fact, finalized within a few days. Clearly the relevant authority is doing a good job in 60

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finalizing the review procedure within such short periods. However, a few projects had to wait for longer periods before their review procedures were finalized. According to a communication by Mr. T. Maluleke (2002) project review and authorization could be concluded within even a shorter period than it was at the time of the investigation. One of the reasons for the longer review and authorization periods is staff shortage in the EIA review office. In Limpopo Province the EIA review office had only five staff members who were responsible for all the EIA review and authorizations in the province for the duration of the investigation. The fact that the Member of the Executive Council (MEC) of the province, i.e. the Provincial Minister of Environment, was the approving authority for EIAs was also considered as another reason for a longer review period. In fact, the EIA regulations require that the MEC delegate the approving powers to the Deputy Director-General (South Africa, 1998), which was not the case for the initial part of the investigation, causing delays in project authorization due to the unavailability of the MEC in some instances. It is likely that appointing another member, with fewer political commitments (for example the Deputy Director-General) as the approving authority could help speed up project authorization, which did eventually take place, and this could have contributed to the shorter review and authorization periods discussed earlier. 4.4 Record of decision Table 6 shows the level in the EIA process at which the ROD was issued. It is clear that the majority of projects (93%) reviewed were authorized at the "scoping report" phase of the EIA process. Projects that were authorized at the "exemption from EIA" phase and the "amended scoping report" phase accounted for 3% and 4% of all the investigated projects, respectively. The exemptions were mainly for upgrading of existing projects that are not likely to have significant impacts on the receiving environment. No projects reached the "environmental impact report" phase in the EIA process. This could be related to the size and nature of the projects submitted for authorization at the Polokwane provincial authority. The type of projects submitted there were generally small and non-complex (for example construction of an irrigation scheme, or an extension of an existing township). A full EIA process would be expected to be required for complex projects, for example industrial projects. Sandham et al. (2002) reported that only 6% of the EIA files they investigated in the North West Province went though a full EIA process. The scenario in Limpopo indicates the extent to which the beefed-up scoping is achieving the aim of speeding up authorisation (Rossouw et al., 2003; Wood, 2003). Table 6 Record of decision (ROD) per activity category and stage of EIA process
Canal Exemption Scoping Report Amended Scoping Report EIR Total No. of Projects 2 15 0 0 17 Power line 0 3 0 0 3 Township 0 13 1 0 14 Resort 0 14 1 0 15 Hazardous substance 0 16 0 0 16 Road 0 9 1 0 10 Change of land use 0 12 0 0 12 Sewage 1 4 0 0 5 Landfill 0 2 1 0 3 Total (%) 3 (3%) 88 (93%) 4 (4%) 0 (0%) 95

The record of decision may be issued with or without conditions. Examples of such conditions may include a monitoring program being put in place; the appointment of a responsible person or even the development of an environmental management plan (EMP). All the investigated projects were authorized with conditions. A comprehensive list of the common ROD conditions appears as Appendix 2 in the 61

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dissertation by Siphugu (2003). It appears that the types of ROD conditions given were relevant and sufficient in most cases. Conditions of authorization appear to be an important sector of the ROD in an attempt to ensure environmental protection. Conditions like provide water education for local communities; dispose waste at a proper waste disposal facility; as many trees as possible should be left on the site; reduce visual impacts are given to ensure environmental protection. Whether or not these conditions are followed closely once the developer has obtained project authorization is an issue that awaits investigation, since post-decision monitoring is not mandated by the ECA regulations. 5 Conclusion and Recommendations Four aspects of EIA practice in the Limpopo Province were investigated in a random stratified sample of 95 files covering nine development project categories. Whilst the frequency of baseline information was generally high (except for economic information) and the quality was predominantly satisfactory and good, there was nevertheless a noticeable fraction of reports with poor or no baseline information. Less than half of all reports contained specialist studies, however, the quality of all specialist studies was acceptable to good, with no noticeable trend regarding occurrence in any particular activity. Recognising that specialist studies are not required for scoping, the low frequency of these studies is nevertheless a matter of concern for EIA effectiveness, since the scoping reports serve the purpose of EIA; hence specialist studies become necessary. The observed duration of projects from application to authorisation is generally less than 12 months, with an average of 6 months. This appears to be an impressively short average, given the shortage of staff in the EIA department, and in view of many complaints that the EIA process takes too long. The investigation revealed that in term of the variables examined, EIA practice in the Limpopo Province is generally in fairly good compliance with regulations, with the exception of the economic baseline data, and in some cases is better than expected, e.g. archaeological specialist studies and social baseline information. However, the investigation and findings have also raised important issues that need urgent attention if the EIA system in Limpopo Province is to take its rightful position as an effective tool in environmental management. The most critical is the understaffing in the EIA office in Limpopo Province and the consequent inability to conduct sufficiently strict and thorough reviews. Shortages in EIA personnel could in turn be due to the lack of properly trained EIA practitioners in Limpopo Province, and South Africa in general. This finding is in agreement with the key challenges for EIA in Southern Africa (Tarr, 2003). This challenge can be address by introducing skills development programs to both the producers of such unsatisfactory EIA data (the consultants) and the reviewers of those reports (relevant authority personnel). It is also important that the provincial as well as the national government embark on recruitment programs to encourage students to follow environmental management studies in universities and technikons. Regulatory requirements that all EIA practitioners should be registered might also help in addressing this problem, and is partially addressed in the new EIA regulations. Some countries have independent EIA review agencies, comprised of various stakeholders, including government and community members that are responsible for 62

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EIA reviews (Momtaz, 2002). Given the gaps that still exist in the EIA review process, and the shortages of EIA review personnel in South Africa, the possibility of introducing such review panels in this country should be seriously explored. Acknowledgements Sincere thanks are due to Mr. T. Maluleke and Mr. Seshoka of the Department of Finance, Economic Affairs and Tourism in Limpopo Province for allowing free access to all the EIA files and also for assistance during the data collection period, and to Prof JH van der Merwe for helpful comments and suggestions on an original draft. References Acocks, J.P.H. (1988). Veld Types of South Africa, 3rd Edition, Government Printer, Pretoria, South Africa. Appiah-Opoku, S., (2001). Environmental impact assessment in developing countries: the case of Ghana, Environmental Impact Assessment Review, 21, 59 - 71. Barker, A. and Wood, C., (1999). An evaluation of EIA system performance in eight EU countries, Environmental Impact Assessment Review, 19, 387 - 404. Beanlands, G., (1988). Scoping methods and baseline studies in EIA, in Wathern, P (ed.), Environmental Impact Assessment: Theory and Practice, Boston: Unwin Hyman. Bregman, J.I., (1999). Environmental Impact Statements, New York: Lewis Publishers. Burdge, R.J. (2002). Why is social impact assessment the orphan of the assessment process? Impact Assessment and Project Appraisal, 20(1), 3-9. Burger B, (2004). Voluntary application of the Integrated Environmental Management guidelines by Eskom in KwaZulu-Natal 1989 1997. Masters dissertation, University of Natal, Durban Chadwick, A. (2002) Socio-economic impacts: Are they still the poor relations in UK environmental Statements? Journal of Environmental Planning and Management, 45(1): 3-24. DEAT, 2002: Specialist studies, Information series 4, Department of Environment Affairs and Tourism (DEAT), Pretoria. Fuggle, R.F., (1992). Environmental evaluation, in Fuggle, R.F. and Rabie, M.A. (eds.), Environmental Management in South Africa, Juta & Co. Ltd., Cape Town. Glasson, J., Therivel, R. and Chadwick, A., (1995). Introduction to Environmental Impact Assessment: Principles and Procedures, Practice and Prospects, UCL Press, London. Holm-Hansen, J., (1997). Environmental impact assessment in Estonia and Norway, Environmental Impact Assessment Review, 17, 449 - 463. Kakonge, J.O., 1999: Environmental Impact Assessment in Africa, In: Petts, J: Handbook of Environmental Impact Assessment, vol 2. , Oxford: Blackwell Science. Lee, N., (1995). Environmental assessment in the European Union: a tenth anniversary, Project Appraisal, 10 (2), 77 - 90.

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Lee, N. & George, C. (2000). Environmental Assessment in Developing and Transitional countries, New York: Wiley & Sons. Leu, W.S., Williams, W.P. and Bark, A.W., (1997). Evaluation of environmental impact assessment in three Southeast Asian nations, Project Appraisal, 12 (2), 89 100. Maluleke, T., (2002). Verbal communication, Polokwane, South Africa. Momtaz, S., (2002). Environmental impact assessment in Bangladesh: A critical review, Environmental Impact Assessment Review, 22, 163-179. Muttamara, S., (1996). Environmental impact assessment (EIA), Resources, Conservation and Recycling, 16, 335 - 349. Office of the Premier of the Northern Province, 1998: Growth and Development Strategy, [Web:] http://www.limpopo.gov.za/economy/gds.html [Date of access: 28 May 2003]. Rossouw, N., Davies, S., Fortuin, H., Rapholo, B., and De Wit, M. (2003). South Africa, In: Southern African Institute for Environmental Assessment, 2003: Environmental Impact Assessment in Southern Africa. Windhoek, Southern African Institute for Environmental Assessment, pp. 201-225 Sandham, L.A., van der Walt, A., and Retief, F. (2002). Aspects of EIA in the North West Province, In Geographical Renaissance at the Dawn of the Millennium: Regional Conference of the International Geographical Union, (IGU 2002 UGI), August 4-7, Durban, South Africa. Sankoh, O. A., (1996). Making Environmental Impact Assessment Convincible to Developing Countries Journal of Environmental Management, 47, 185189. Siphugu, M.V. (2003). An appraisal of the environmental impact assessment (EIA) practice in Limpopo Province. M.Sc. Mini-dissertation, Potchefstroom University for Christian higher Education, Potchefstroom, South Africa. South Africa, (1989). The Environment Conservation Act, Act No. 73 of 1989, Pretoria: Government Printer. South Africa, (1997). Regulations under the Environment Conservation Act, Act 73 of 1989 - Regulations 1182, 1183 & 1184 of September 1997, Pretoria: Government Printer. South Africa, (1998). The National Environmental Management Act, Act No. 107 of 1998, Pretoria: Government Printer. South Africa, (2004a). Regulations under Section 107(1) of the Mineral and Petroleum Resources Development Act, Act 28 of 2002 Regulation R527 of 23 April 2004. Gazette No. 7949, Vol. 466 No. 26275, Pretoria: Government Printer. South Africa, (2004b). Proposed regulations under Section 24(5) of the National Environmental Management Act, 1998 (Act 107 of 1998) as amended. Pretoria: Government Printer. Tarr, P. (2003). EIA in southern Africa: Summary and future focus. In Southern African Institute for Environmental Assessment, 2003: Environmental Impact Assessment in Southern Africa. Windhoek, Southern African Institute for Environmental Assessment, pp. 329-337

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Tshivhandekano, T.R. (2003). Some aspects of the environmental impact assessment in Limpopo Province, Unpublished M.Sc. Mini-dissertation, Potchefstroom University for Christian Higher Education, Potchefstroom, South Africa. Vanclay, F. (1999). Social impact assessment. In Petts, J: Handbook of Environmental Impact Assessment, vol 2. , Oxford: Blackwell Science, 301-326. Wathern, P. (1988). An introductory guide to EIA. In Wathern, P. (ed.), Environmental Impact Assessment: Theory and Practice, Boston: Unwin Hyman. Wathern, P. (1999). Ecological impact assessment. In Petts, J: Handbook of Environmental Impact Assessment, vol 2. , Oxford: Blackwell Science, 326-346. Wood, C. (1999). Pastiche or postiche? Environmental impact assessment in South Africa, South African Geographical Journal, 81 (1), 52 - 59. Wood, C., (2003). Environmental Impact Assessment: A Comparative Review Second Edition, Harlow, England: Pearson.

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