Abstract
M.Sc. (Environmental Management)
Environmental Management Plans (EMPs) are legally binding documents that are submitted in fulfillment of the minimum requirements prescribed in the Mineral and Petroleum Resource Development Act (Act No. 28 of 2002) [MPRDA] and the 2010 EIA Regulations under the National Environmental Management Act (Act No. 107 of 1997) [NEMA]. The information in the EMP contains an explanation of the mitigation measures, time and location for implementation, anticipated results, roles and responsibilities for implementation within the organisation involved as well as reporting measures. Despite the importance of EMPs during the Environmental Impact Assessment (EIA) process, as well as in the operation and decommissioning of projects, there is scarcity of scientific studies focusing on the evaluation of EMP quality in South Africa.
The present study has focused on the evaluation of the quality of EMPs for selected mining projects in South Africa. Apart from evaluating the quality aspects, other research objectives involved the analysis of strengths and weaknesses inherent in the EMPs reviewed. Fifteen (15) EMPs were assessed using the modified Lee and Colley Review Package. The results showed that 75% of the EMPs were satisfactorily constituted. Only 47% of the EMPs were graded as satisfactory and complete (“B”), whilst 27% of the EMPs were of borderline and unsatisfactorily (“D”) quality.
The Review Area 1 which is pertaining to the description of the environment and development was the best performed. On the other hand, the Review Area 4, which focused on the planning aspects of the EMP was the worst performed of all Review Areas, with information that was considered insufficient, especially on tasks that were relating to complaints management procedures and performance assessment procedures. Review Area 3 was also allocated a low performance score. This raised concerns as to the limited extent to which EMPs assessed appear to comply to the minimum requirements of the South African environmental legislation, namely 2010 EIA Regulations and MPRDA.
Since the sample used for the research was small, further research is required to expand the scope of these EMP quality reviews. It is also recommended that a standard EMP template be developed for the South African EIA processes, that will be on par with international standards of excellence and will ensure that there is no ambiguity on what constitutes a comprehensive EMP.