EMP Guide

GUIDELINES FOR STANDARDISED
ENVIRONMENTAL MANAGEMENT PLANS

FOR
DEPARTMENT OF WATER AFFAIRS
AND FORESTRY PROJECTS.
Prepared for:
Department of Water Affairs and Forestry

Directorate: Social and Ecological Services
Prepared by:
CSIR
Division of Water Environment and Forestry Technology
DATE:
May 2002
Executive Summary
These guidelines for standardised Environmental Management Plans (EMPs) have been
developed as part of the Department of Water Affairs and Forestrys (DWAF) initiative to
ensure that Integrated Environmental Management principles are implemented within the
Departments functions. The purpose of this initiative is to ensure compliance with
environmental legislation and to promote sustainable environmental practice.
DWAF: Water Resource Management propose to standardise the EMPs that will be required
by the new Integrated Environmental Management Regulations which are currently being
developed by the Department of Environmental Affairs and Tourism. The EMPs will be
produced by DWAF project managers in certain cases (in-house projects), or the contractors
and their environmental consultants in other cases. Guidelines on what DWAF require in the
EMPs will enable the efficient
production of these
plans. By standardising the EMPs, review and information finding within the plans will be
made easier and the efficient monitoring of EMP implementation will be facilitated. These
guidelines are therefore, applicable to all DWAF staff, specifically those involved in Water
Resource Management, who:
develop terms of reference for projects;
approve project proposals from consultants;
commission contracts with consultants; and
monitor project implementation;
In addition, these guidelines are designed to assist those parties involved in the project
implementation and operational phases of DWAF Water Resource Management funded
projects. Relevant parties include the:
project planning team;
consulting engineers;
contractors and sub-contractors;
environmental consultants and sub-consultants and
affected parties.
The guidelines begin by providing basic background information on Integrated Environmental
Management in DWAF as well as the current and expected legislation requiring the
implementation of EMPs. Then information on generic guidelines for the development of an
EMP, as required by DWAF, is provided. This chapter provides a brief explanation of each of
the sections that should be included in the contents of an EMP and is the crux of the
guideline document. Finally, a brief description is provided of the most common generic
impacts with regard to Water Resource Management projects and activities and the required
generic mitigation measures.
Draft guidelines for standardised EMP for DWAF projects (May 2002)
Acronyms and abbreviations

APP:
CEIMP:
DEAT:
DWAF:
ECO:
EES:
EIA:
EIR:
EMF:
EMP:
EMS:
ESM & RS:
IEM:
NEMA:
RE:
SEA:
SES:
Approved Professional Person

Consolidated Environmental Implementation and Management Plan
Department of Environmental Affairs and Tourism
Department of water Affairs and Forestry
Environmental Controlling Officer under the employ of DWAF or employed as
an outside Consultant to DWAF.
Environmental Evaluation System
Environmental Impact Assessment
Environmental Impact Report
Environmental Management Framework
Environmental Management Plan
Environmental Management System
Environmental Site Management and Rehabilitation Specifications
Integrated Environmental Management
National Environmental Management Act (Act No 107 of 1998)
The Resident Engineer under the employ of DWAF.
Strategic Environmental Assessment
Directorate: Social and Ecological Services
Glossary
To assist with the understanding of this guideline, commonly used terms relevant to
Environmental Management Plans and to DWAF projects are described.
Approved Professional Person
. Also referred to as the project manager in this document.
Auditing
A systematic, documented, periodic and objective evaluation of how well the environmental
management plan is performing with the aim of helping to safeguard the environment by:
facilitating management control of which would include meeting regulatory requirements.
Authority
National, regional or local authority, that has a decision-making role or interest in the
development.
Compensation
Trade-offs between different parties affected by the proposed development to the mutual
satisfaction of all concerned parties.
Contractor
Individual and/or company responsible for the construction activities, the related activities
and the implementation of the environmental management plan. In the case where DWAF is
the Contractor, the Resident Engineer will be addressed as the Contractor. Otherwise, the
Contractor is a private contractor qualified to Tender for DWAF projects.
Contractors representative
Person on the site representing the Contractor who is knowledgeable in environmental
issues and is responsible for the implementation of the findings of the environmental plan.
ii
Corrective (or remedial) Action

Reactive response required to address an environmental problem that is in conflict with the
requirements of the EMP. The need for corrective action may be determined through
monitoring, audits or management review.
Cumulative impact
An action that in itself is not significant but is significant when added to the impact of other
activities in the area.
Project manager
Department of Water Affairs and Forestry representative charged with coordinating and
managing the various stages of a project.
Environment
According to NEMA, the environment is the surroundings within which humans exist, being
made up of:
the land, water and atmosphere of the earth;
micro-organisms, plant and animal life;
any plant or combination of i) and ii) and the interrelationships among and between
them; and
the physical, chemical, aesthetic and cultural properties and conditions of the above
that influence human health and well-being.
However, for the purposes of this document the environment includes both the bio-physical
as well as the social and economic aspec ts of the area.
Environmental Management Plan Audit (EMP Audit)
A systematic, documented and objective evaluation of the environmental performance of a
project by obtaining and analysing evidence to determine whether the implementation of the
EMP conforms with its requirements (Swaziland Environmental Authority, 1999).
Environmental Impact
Change in an environment resulting from the effect of an activity on the environment,
whether positive or negative. Impacts may be the direct consequence of an individuals or
organisations activities or may be indirectly caused by them (DEAT, 1998).
Environmental Impact Assessment (EIA)
The process of examining the environmental effect of development (DEAT, 1998). It is the
process of assessing and incorporating potentially significant environmental impacts into the
planning, design, approval and implementation of a project.
Environmental Management System (EMS)
That part of the overall management system that includes organisational structure, planning
activities, responsibilities, practices, procedures, processes and resources for developing,
implementing, achieving, maintaining and reviewing an environmental policy.
Environmental Objective
Overall environmental goal as stated in the EMP.
Environmental Policy
Statement of intent and principles in relation to overall environmental performance, providing
a framework for the setting of objectives and targets.
iii
Environmental Risk
The probability of a prescribed undesirable effect. Risks result from the existence of a hazard
and uncertainty about its expression (Suter, 1993).
Environmental Target
Detailed requirement against which performance may be assessed, quantified where
practicable, arising from an environmental objective and that needs to be met in order to
achieve the associated objective. A target against which performance can be assessed.
Interested and Affected Party (I&AP)
Individuals or groups concerned with, or affected by, an activity and its consequences. These
include the authorities, local communities, investors, work force, customers and consumers,
environmental interest groups and the general public (DEAT, 1998).
Mitigation
Measures designed to avoid, reduce or remedy adverse impacts (DEAT, 1998).
Monitoring
The repetitive and continued observation, measurement and evaluation of environmental
criteria to follow changes over a period of time and to assess the efficiency of control
measures (DEAT, 1998).
Preventative Action
A predetermined action to address potential problems before they develop into situations
which would be contrary to the requirements of the EMP. Preventative action is most often
determined from the results of monitoring and audits during management review.
Project Appraisal
The collection and evaluation of detailed information concerning a proposed project, usually
to assess risk associated with it.
Pollution
The residue of human activity which adversely affects the next user or environmental
resource.
Significant impact
An impact that has crossed the threshold of significance.
Site specific investigation
An assessment or evaluation of the impact of the proposed development on the immediate
environment.
Acknowledgements
These guidelines were produced with input from a number of Department of Water Affairs
and Forestry staff members, both within the national office and provincial offices.
Representatives from the Department of Environmental Affairs and Tourism also provided
comments on the document. All those who participated in the mini-workshops and the
stakeholder workshop or provided comment on draft versions of the guidelines are thanked
for their contribution.
iv
TABLE OF CONTENTS
EXECUTIVE SUMMARY ........................................................................................................ I
ACRONYMS AND ABBREVIATIONS................................................................................. II
GLOSSARY ............................................................................................................................. II
ACKNOWLEDGEMENTS.....................................................................................................IV
TABLE OF CONTENTS.........................................................................................................V
TABLE 4.1: GENERIC BIOPHYSICAL IMPACTS AND ASSOCIAT ED GENERIC
MITIGATION MEASURES. ......................................................................................................VI
TABLE 4.2: GENERIC SOCIO-ECONOMIC IMPACTS AND ASSOCIATED GENERIC
MITIGATION MEASURES. ......................................................................................................VI
1.
INTRODUCTION .............................................................................................................1
1.1
1.2
1.3
1.4
1.5
1.5.1
1.5.2
1.5.3
1.5.4
1.6
2.
USERS GUIDE ..............................................................................................................12

2.1
2.2
2.3
2.4
3.
BACKGROUND TO INTEGRATED ENVIRONMENTAL MANAGEMENT IN DWAF............1

BACKGROUND TO THE DEVELOPMENT OF THE GUIDELINE DOCUMENT......................1
WHAT IS AN ENVIRONMENTAL MANAGEMENT PLAN?................................................1
THE ROLE OF ENVIRONMENTAL MANAGEMENT PLANS WITHIN INTEGRATED
ENVIRONMENTAL MANAGEMENT AND WHERE THESE LINK INTO THE
ENVIRONMENTAL MANAGEMENT FRAMEWORK .........................................................2
ENVIRONMENTAL MANAGEMENT PLANS AND THE SOUTH AFRICAN ENVIRONMENTAL
LEGISLATION ...............................................................................................................5
LEGISLATION REQUIRING THE DEVELOPMENT OF DEPARTMENTAL CONSOLIDATED
ENVIRONMENTAL IMPLEMENTATION AND MANAGEMENT PLANS ...........................5
LEGISLATION REQUIRING THE DEVELOPMENT OF PROJECT ENVIRONMENTAL
MANAGEMENT PLANS.............................................................................................5
NEMA PRINCIPLES TO GUIDE THE DEVELOPMENT OF ENVIRONMENTAL
MANAGEMENT PLANS .............................................................................................8
ACTIVITIES THAT REQUIRE ENVIRONMENTAL ASSESSMENT BY LAW ..................10
TERMS OF REFERENCE FOR THE DEVELOPMENT OF THESE EMP GUIDELINES......10
WHY STANDARDISED GUIDELINES ARE REQUIRED BY DWAF.................................12
WHO SHOULD USE THIS GUIDELINE DOCUMENT.......................................................12
ENVIRONMENTAL MANAGEMENT PLAN GUIDELINE STRUCTURE AND CONTENTS ....12
HOW TO USE THIS GUIDELINE DOCUMENT................................................................13
GENERIC GUIDELINES ..............................................................................................14

3.1
WHO SHOULD DEVELOP THE EMP...........................................................................14
3.2
KEY STEPS IN DEVELOPING AN ENVIRONMENTAL MANAGEMENT PLAN..................14
3.2.1
REVIEW OF AVAILABLE INFORMATION ..................................................................14
3.2.2. DETERMINE THE SENSITIVITY OF THE PROJECT...................................................15
3.2.3
ASSESS IMPACTS AND MITIGATION MEASURES ....................................................15
3.2.4
DEVELOP THE CONTENTS OF THE ENVIRONMENTAL MANAGEMENT PLAN..........16
3.3
WHAT AN ENVIRONMENTAL MANAGEMENT PLAN SHOULD INCLUDE .......................16
3.3.1
SUMMARY OF THE ACTIVITY/PROJECT BACKGROUND INFORMATION ...................17
3.3.2
SUMMARY OF THE NEGATIVE IMPACTS TO BE MITIGATED ....................................18
3.3.3
DESCRIPTION OF THE MITIGATION MEASURES .....................................................18
3.3.4
PERFORMANCE SPECIFICATIONS .........................................................................19
v
3.3.5
SUMMARY OF THE POSITIVE IMPACTS ..................................................................19
3.3.6
DESCRIPTION OF THE ACTIONS REQUIRED TO ENHANCE THE POSITIVE IMPACTS19
3.3.7
COMMUNITY UPLIFTMENT MEASURES ..................................................................19
3.3.8
COST ESTIMATES OF MITIGATION MEASURES ......................................................20
3.3.9
DESCRIPTION OF THE MONITORING PROGRAMME................................................21
3.3.10 INSTITUTIONAL ARRANGEMENTS : ROLES AND RESPONSIBILITIES ........................22
3.3.11 TRAINING AND CAPACITY BUILDING REQUIREMENTS............................................23
3.3.12 PUBLIC PARTICIPATION PROCESS TO BE FOLLOWED ...........................................23
3.3.13 IMPLEMENTATION SCHEDULE ...............................................................................24
3.3.14 ENVIRONMENTAL AWARENESS PROCESS TO BE FOLLOWED ...............................24
3.3.15 DOCUMENTATION, RECORD KEEPING AND REPORTING PROCEDURES ................25
3.4
AUDITING THE IMPLEMENTATION OF AN ENVIRONMENTAL MANAGEMENT PLAN.....26
3.5
TRANSLATION OF EMP REQUIREMENTS INTO TENDER DOCUMENTS FOR SUBCONSULTANTS ..........................................................................................................27
3.6
CONDITIONS UNDER WHICH THE ENVIRONMENTAL MANAGEMENT PLAN SHOULD BE
REVISED....................................................................................................................28
3.7
CONSIDERATION OF DEPARTMENTAL DOCUMENTATION DURING THE DEVELOPMENT
AND IMPLEMENTATION OF AN ENVIRONMENTAL MANAGEMENT PLAN.....................29
4.
4.1
5.
GENERIC IMPACTS AND THE ASSOCIATED GENERIC MITIGATION

MEASURES FOR DWAF WATER RESOURCE MANAGEMENT PROJECTS 30
INTRODUCTION .......................................................................................................30
REFERENCES...............................................................................................................53
Table 3.1:
An example of an audit procedure.
Table 4.1:
Generic biophysical impacts and associated generic mitigation measures.
Table 4.2:
Generic socio-economic impacts and associated generic mitigation measures.
vi
1.
Introduction
1.1
Background to Integrated Environmental Management in DWAF
In 1989 the Department of Water Affairs and Forestry (DWAF) formulated the departmental
procedures for applying the IEM process. Since then DWAF has endeavoured to apply
elements of Integrated Environmental Management (IEM) to the Departments development
projects. These procedures were amended to ensure compliance with the National IEM
Guideline Series of 1992.
Recent South African environmental legislative developments (refer to Chapter 3 of the
Environmental Management Framework (DWAF,2002a)) have necessitated the updating
and alignment of DWAFs 1995 IEM procedures with international trends and the current
national environmental assessment and management requirements.
The need for integrated and overarching Departmental IEM procedures is strengthened by
the overlapping environmental considerations of several Departmental policies, guidelines
and regulations.
DWAF has proactively addressed these needs by initiating a five-phase project entitled
Revision of the Integrated Environmental Management and Development of an
Environmental Management Framework within DWAF. The first phase of this project
includes developing these guidelines for standardised EMPs for use by the Departments
Water Resource Management Branch. The remaining phases will focus on implementation,
application and capacity building.
In addition to the fact that not all DWAF projects have, or implement, an EMP, there is
currently no standard format for EMPs. However, a generic EMP has recently been
developed for DWAF Northern Province Regional Office (DWAF 2001). This document
describes how generally occurring negative environmental impacts will be managed,
rehabilitated and monitored and positive impacts maximised.
1.2
Background to the development of the guideline document
This guideline document has been developed as part of DWAFs initiative to ensure that IEM
principles are implemented within the Departments functions, in order to ensure compliance
with environmental legislation and to promote sustainable environmental practice.
DWAF: Water Resource Management propose to standardise the EMPs that will be required
by the new IEM Regulations. The EMPs will be produced by DWAF project managers in
certain cases (in-house projects), or the contractors and their environmental consultants in
other cases. Guidelines on what DWAF require in the EMPs will enable the efficient
production of these EMPs. By standardising the EMPs, review and information finding within
the plans will be made easier and the efficient monitoring of EMP implementation will be
facilitated.
1.3
What is an Environmental Management Plan?
Environmental Management Plans (EMPs) are important tools that bridge the gap between
the completion of the Environmental Impact Assessment (EIA) and the implementation of the
project, particularly with regard to implementing the mitigation measures recommended in
the Environmental Impact Report (EIR) and then monitoring, auditing and taking corrective
actions during their implementation. An EMP is typically drawn up after an EIA or SEA and is
implemented during the construction phase and in some cases, such as in the mining
industry, throughout the project lifecycle up to and including decommissioning. An EMP
allocates responsibility, resources and deadlines to each of the actions. An EMP must detail
actions to ensure compliance with regulatory bodies and that environmental performance is
verified through information on impacts as they occur.
An EMP must:
define the various measures to be taken during the life of a project (pre-construction,
construction, operation and decommissioning) in order to enhance positive and minimise
adverse environmental effects and meet the performance specifications;
define the actions needed to implement these measures;
describe how this will be achieved; and
allocate responsibilities.
EMP implementation is a cyclical process that converts mitigation measures into actions and
through cyclical monitoring, auditing, review and corrective action, ensures conformance with
stated EMP aims and objectives.
An EMP must respond to unforeseen events and changes in project implementation that
were not considered in the EIA. Through monitoring and auditing, feedback for continual
improvement in environmental performance must be provided and corrective action taken to
ensure that the EMP remains effective.
The objectives of an EMP should include (Hill, 2000):
ensuring compliance with regulatory authority stipulations which may be local,

national and/or international;
ensuring that there is sufficient allocation of resources so that the scale of EIA followup activities is consistent with the significance of project impacts;
verifying environmental performance through information on impacts as they occur;
responding to changes in project implementation not considered in the EIA;
responding to unforeseen events; and
providing feedback for continual improvement in environmental performance.

1.4
The role of Environmental Management Plans within Integrated Environmental

Management and where these link into the Environmental Management
Framework
Environmental management, in terms of the current IEM guidelines, EIA regulations and
environmental legislation, generally operates in the following manner and sequence:
1)
The EIA, a regulatory requirement for specified activities, takes place during the
project planning and design phases and strives to identify potential project impacts for
which appropriate impact mitigation measures are devised.
2)
The EMP, although not a requirement enforced by DEAT, may be requested by the
authorities as a condition of the Record of Decision, in support of the EIA and is
commonly carried out during the project construction phase. The EMP may
sometimes continue into the operational phase depending on the nature of the
project. The EMP strives to convert the mitigation measures into actions for
3)
implementation and in this regard deals with responsibilities, resources and

scheduling.
The Environmental Management System (EMS) is a management system that is
generally organization-specific rather than project-specific and is implemented during
the operational phase, providing a framework for organizational structures, reporting,
internal and external communication, monitoring and review, and training.
These three tools (EIA, EMP and EMS) essentially compliment each other in a variety of
ways and overlap with regards to many of their principles, objectives and requirements. The
associations between the three tools may be described as the EIA predicting potential
impacts, the EMP managing the impacts and the EMS providing an overarching framework
for managing the EIA and EMP and which requires the EIA and EMP for its implementation.
The critical link in terms of developing an EMP is the information that precedes it, or feeds
into it. The key source of this information is the Environmental Assessment (EA), which has
to date usually been the EIA, and it is therefore essential that the EA is undertaken to a
sufficiently detailed level, ensuring that relevant, accurate and appropriate information on
impacts and mitigation is fed through to the EMP. It is important to note that an EA may not
necessarily have been completed for a project or activity requiring an EMP. This does not
alter the importance of the need for information essential to the EMP.
The EMP is compiled during the fifth phase of the project life cycle (Detailed Design phase)
according to Figure 1 (Figure 3 in the Department Environmental Management Framework
(EMF) (DWAF, 2002a)). The EMP is implemented in the sixth and seventh phases,
monitoring and auditing occurring during the seventh phase according to the EMP. During
the next, and last, phase of the project life cycle the EMP requirements for decommissioning,
rehabilitation and monitoring are implemented. Figure 1 of the EMF indicates where the
EMP, as an Environmental Assessment and Management Tool, fits within the overall
framework.
EA
LEGEND
FEASIBILITY & RE- APPRAISAL

DETAILED EA
DESIGN OF MITIGATION
MEASURES
REVIEW
PROJECT LIFECYCLE
PRE-FEASIILITY & RE- APPRAISAL

SITE SELECTION
INITIAL EA
SCOPING OF SIGNIFICANT
ISSUES & REVIEW
PROJECT IDENTIFICATION
SCREENING
PROJECT TYPE & LEGISLATION
ENVIRONMENTAL SENSITIVITY
APPROPRIATE EA TOOL
CLOSURE & DECOMMISIONING

DISMANTLING &
REHABILITATION
AFTERCARE
EMP REHABILIATION PLAN
MONITORING,
AUDITING & REVIEW
EMP requirements
for decomm.,
rehab. &
monitoring
implemented
8
EMS
ENGINEERING PHASES
IEM
PROJECT APPROVAL
RECORD OF DECISION
CONDITIONS OF APPROVAL
CONCEPTION TO
PLANNING &
DESIGN
IMPLEMENTATION TO
DECOMMISSIONING &
REHABILITATION
DETAILED DESIGN,
ENGINEERING, TENDER,
CONTRACTOR SELECTION &
APPOINTMENT
APPRAISAL & CHANGES
DETAILED DESIGN OF EMP
INCORPORATION OF SM&RS
IMPLEMENTATION
CONSTRUCTION &
COMMISSIONING
EMP TRAINING & CAPACITY
BUILDING
CONSTRUCTION PHASE
EMP IMPLEMENTATION
EMP compiled
EMP finalised
5
EMP implementation
6
OPERATION & MAINTENANCE
EXPANSION & MODIFICATION
OPERATIONAL PHASE
EMP IMPLEMENTATION
MONITORING,
AUDITING & REVIEW
EMP implementation &

EMS
Figure 1:
Linking Environmental Assessment, Environmental Management Plans and

Environmental Management Systems to the Project Lifecycle and Engineering
Phases.
1.5
1.5.1
Environmental Management Plans and the South African environmental

legislation
Legislation requiring the development of Departmental Consolidated
Environmental Implementation and Management Plans
Sections 11 and 15 of NEMA impose an obligation on DWAF to develop an environmental

implementation plan and environmental management plan containing the information
prescribed by section 13. In accordance with this, DWAF has submitted a consolidated
Environmental Implementation and Management Plan (CEIMP) to the Committee of
Environmental Co-ordination. The CEIMP has been approved by the CEC and it has been
gazetted (Government Gazette No 22929). A requirement of this CEIMP, is that the
department must develop guidelines for standardised EMPs that are to be developed for all
their in-house and subcontracted projects.
1.5.2
Legislation requiring the development of project Environmental Management

Plans
Prior to the South African EIA Regulations (Department of Environmental Affairs and
Tourism, 1998), EIAs were undertaken on a voluntary basis by certain large projects that
were typically the focus of considerable public concern and controversy.
Integrated Environmental Management Procedure Guideline documents were produced by
the Department of Environmental Affairs and Tourism (DEAT) in 1992. These guidelines
emphasised cradle-to-grave environmental management, particularly impact management.
However, the 1997 EIA Regulations focus on the role of EIA in decision-making (compulsory
EIAs for specified activities), and do not consider project implementation. This may be due
to the fact that the regulations were promulgated under Section 21 of the Environmental
Conservation Act (Act 73 of 1989), which predates the 1992 IEM guidelines (Hill, 2000).
Given the current focus of EIA ending at the project approval phase, there is a clear need for
both the EIA regulations and the environmental legislation to be aligned with South African
IEM principles and requirements for sustainable development.
Subsequent to the EIA Regulations, the National Environmental Management Act (Act 107 of
1998) (NEMA) has been promulgated. Currently, NEMA makes only limited reference to EIA
follow-up, and therefore EMP requirements, in the chapter on IEM (Chapter 5). However, the
Department of Environmental Affairs and Tourism (DEAT) is in the process of updating
NEMA and developing new IEM Regulations. According to preliminary discussions with
DEAT, it is envisaged that these Regulations will require the development of EMPs for all
projects. This is discussed further in section 1.5.4 below.
Currently, Section 24(1) of NEMA imposes the obligation that proponents of all
developments, projects and activities that may impact on the environment, undertake an
assessment of environmental & social impacts. Section 3(a) states that the required
assessment must take place in accordance with procedures complying with subsection 24
(7), which requires an:
(c)
investigation of mitigation measures to keep adverse impacts to a minimum, as well

as the option of not implementing the activity;
and:
(f)
investigation and formulation of arrangements for the monitoring and management of

impacts, and the assessment of the effectiveness of such arrangements after their
implementation.
While this Section is currently not enforced by DEAT, DWAF should take this requirement
into account and apply it for all their projects and activities. DEAT is, however, currently
revising Chapter 5 of NEMA, while also drafting national IEM Regulations to assist
compliance. It is envisaged that these Regulations will require that EMPs be developed for
all development projects. Figure 2 provides a flow diagram of the process expected to be
required in the new IEM Regulations (pers. comm, P Lazarus). Once these Regulations
have been promulgated, all projects that are approved will either be approved subject to
implementation of (i) a mini-EMP; or (ii) a comprehensive EMP, for projects in more sensitive
areas or with more substantial significant negative impacts. Therefore, all DWAF projects
that are proposed for environmentally sensitive areas will require a comprehensive EMP.
Incorporating EMPs as a follow-on part of the EA process, will help to ensure that
environmental objectives and targets are met and maintained. In particular, the EMP will
strengthen the current process by addressing schedules, resources (manpower, financial
and equipment), responsibilities, methods and procedures for post EIA decision
implementation (Pero, 2001).
Activities within
environmentally sensitive
environments
Land use policies,

programmes, plans and
projects
New activities
Application
Screening Report
Environmental Authority Review
No or little
impact
ROD
Further investigation
necessary
No go
ROD
Public
participation
Public
participation
Environmental
Authorisation
Refusal of
Environmental
Authorisation
Appeal
Appeal
Terms of Reference for

Environmental
Assessment (Scoping
Report)
Public
participation
Environmental Assessment
Report with mini environment
management plan (EMP)
Public
participation
Public participation
Environmental Authority
Review
ROD
ROD
ROD
Environmental Authorisation in
accordance with mini EMP
Environmental Authorisation subject

to comprehensive EMP
Refusal of Environmental
Authorisation
Appeal
Appeal
Public
participation
Compliance reports
Environmental
Authority review
Environmental Management
Plan
Ongoing
ROD
ROD
Environmental Authorisation in
accordance with EMP
Refusal of Environmental
Authorisation
Appeal
Appeal
Compliance reports
Ongoing
Environmental
Authority review
Figure 2:
The process expected to be required in the new IEM Regulations.
1.5.3
NEMA principles to guide the development of Environmental Management

Plans.
The following NEMA principles should guide (i) any actions by DWAF that may significantly
affect the environment; (ii) decisions concerning the protection of the environment; and of
particular relevance: (iii) development of environmental management plans.
Sec. 2 (2) Environmental management must place people and their needs at the forefront
of its concern, and serve their physical, psychological, developmental, cultural and
social interests equitably.
(3)
Development must be socially, environmentally and economically sustainable.
(4)(a) Sustainable development requires the consideration of all relevant factors including
the following:
(i)
disturbance of ecosystems and loss of biological diversity are avoided, or,
where they cannot be altogether avoided, are minimised and remedied;
(ii)
pollution and degradation of the environment are avoided, or, where they
cannot be altogether avoided, are minimised and remedied;
(iii)
disturbance of landscapes and sites that constitute the nation's cultural
heritage is avoided, or where it cannot be altogether avoided, is minimised
and remedied;
(iv)
waste is avoided, or where it cannot be altogether avoided, minimised and reused or recycled where possible and otherwise disposed of in a responsible
manner;
(v)
use and exploitation of non-renewable natural resources is responsible and
equitable, and takes into account the consequences of the depletion of the
resource;
(vi)
development, use and exploitation of renewable resources and the
ecosystems of which they are part do not exceed the level beyond which their
integrity is jeopardised;
(vii)
risk-averse and cautious approach is applied, which takes into account the
limits of current knowledge about the consequences of decisions and actions;
and
(viii)
negative impacts on the environment and on people's environmental rights be
anticipated and prevented, and where they cannot be altogether prevented,
are minimised and remedied.
(b)
Environmental management must be integrated, acknowledging that all elements of

the environment are linked and interrelated, and it must take into account the effects
of decisions on all aspects of the environment and all people in the environment by
pursuing the selection of the best practicable environmental option.
(c)
Environmental justice must be pursued so that adverse environmental impacts shall

not be distributed in such a manner as to unfairly discriminate against any person,
particularly vulnerable and disadvantaged persons.
(d)
Equitable access to environmental resources, benefits and services to meet basic

human needs and ensure human well-being must be pursued and special measures
may be taken to ensure access thereto by categories of persons disadvantaged by
unfair discrimination.
(e)
Responsibility for the environmental health and safety consequences of a policy,

programme, project, product, process, service or activity exists throughout its life
cycle.
(f)
The participation of all interested and affected parties in environmental governance

must be promoted, and all people must have the opportunity to develop the
understanding, skills and capacity necessary for achieving equitable and effective
participation, and participation by vulnerable and disadvantaged persons must be
ensured.
(g)
Decisions must take into account the interests, needs and values of all interested and
affected parties, and this includes recognising all forms of knowledge, including
traditional and ordinary knowledge.
(h)
Community well-being and empowerment must be promoted through environmental

education, the raising of environmental awareness, the sharing of knowledge and
experience and other appropriate means.
(i)
The social, economic and environmental impacts of activities, including

disadvantages and benefits, must be considered, assessed and evaluated, and
decisions must be appropriate in the light of such consideration and assessment.
(j)
The right of workers to refuse work that is harmful to human health or the
environment and to be informed of dangers must be respected and protected.
(k)
Decisions must be taken in an open and transparent manner, and access to

information must be provided in accordance with the law.
(l)
There must be intergovernmental co-ordination and harmonisation of policies,

legislation and actions relating to the environment.
(m)
Actual or potential conflicts of interest between organs of state should be resolved

through conflict resolution procedures.
(n)
Global and international responsibilities relating to the environment must be

discharged in the national interest.
(o)
The environment is held in public trust for the people, the beneficial use of
environmental resources must serve the public interest and the environment must be
protected as the people's common heritage.
(p)
The costs of remedying pollution, environmental degradation and consequent

adverse health effects and of preventing, controlling or minimising further pollution,
environmental damage or adverse health effects must be paid for by those
responsible for harming the environment.
(q)
The vital role of women and youth in environmental management and development
must be recognised and their full participation therein must be promoted.
(r)
Sensitive, vulnerable, highly dynamic or stressed ecosystems, such as coastal

shores, estuaries, wetlands, and similar systems require specific attention in
management and planning procedures, especially where they are subject to
significant human resource usage and development pressure.
According to Section 28 of NEMA, whenever a DWAF activity, function or project causes,

has caused or may cause significant pollution or degradation of the environment, DWAF
must take reasonable measures to prevent such pollution or degradation from occurring,
continuing or recurring. In so far as such harm can be reasonably avoided (or is authorised
by law), the pollution/degradation must be minimized and rectified. Examples of reasonable

measures envisaged by NEMA, and which must be written into all the EMPs developed for
DWAF projects, include:
investigate, assess and evaluate the impact on the environment;
inform and educate employees about the environmental risks of their work and the
manner in which their tasks must be performed in order to avoid causing significant
pollution or degradation of the environment;
cease, modify or control any act, activity or process causing the pollution or
degradation;
contain or prevent the movement of pollutants or the causing of degradation;
eliminate any source of the pollution or degradation; or
remedy the effects of the pollution or degradation.
1.5.4
Activities that Require Environmental Assessment by law
Activities currently listed in the Section 21 of the Environmental Conservation Act, 1989 (Act
73 of 1989) which will probably have a detrimental effect on the environment, require an EIA.
Those listed activities which DWAF might be involved in include:
land use and transformation, such as construction of dams;
water use and disposal, such as water resource and service management;
transportation, such as bulk transport of water (pipelines);
chemical treatment, such as purification works; and
waste disposal and sanitation, as at all construction sites.
In the revised NEMA Chapter five and the IEM Regulations, it is expected that activities
which will require an EA are those that will take place in sensitive environments, or that may
have a substantial detrimental effect on the environment, and therefore require
environmental authorisation by the Minister, MEC or municipality. The list of activities
requiring a mandatory EA, will change at all three levels of government. It will be important
for DWAF, operating across these three levels of government, to keep abreast of the new
listings. All other activities, also referred to as unlisted activities, are regulated by section 25
of NEMA, which provides a framework in terms of which of these unlisted activities require an
EA.
1.5.5
National Water Act
The National Water Act (Act 36 of 1998), which is administered by DWAF, and to which is
bound by its provisions, has three main principles: equity in access to water; optimal
beneficial use of water; and sustainability. These three principles must be taken into account
when conducting the impact assessment of an EA for a project and particularly when
developing and EMP. Therefore, it is clear that not only biophysical, but also social and
economic sectors of the environment must be considered, and negative impacts on these
sectors mitigated in the EMP.
1.6
Terms of Reference for the development of these EMP guidelines
This document has been written according to the CSIR/DWAF agreed Terms of Reference
(ToR) detailed in CSIR Environmenteks revised proposal Revision of the Integrated
Environmental Management Procedures and Development of an Environmental
Management Framework within the Department of Water Affairs and Forestry submitted to
the DWAF on 8 August 2001 and approved by the DWAF on 5 September 2001. The ToR
require the CSIR to provide the DWAF Directorate: Social and Ecological Services (SES)
10
with guidelines for standardised EMPs for all DWAF projects, with the emphasis on the
projects and activities undertaken by the Water Resource Management Branch of DWAF.
11
2.
Users guide
2.1
Why standardised guidelines are required by DWAF
An EMP can take any number of formats, include information for certain sections to varying
degrees and present the requirements in different ways. While the format needs to suit the
circumstances of the project for which the EMP is developed and the requirements that it is
designed to meet, the format of EMPs produced for DWAF projects should, to a large extent,
be standardised. This will facilitate the review of the EMP and information finding within the
plan as well as facilitate the monitoring of the implementation of the required mitigation
measures.
These guidelines serve as a management tool to assist DWAF staff, at a strategic level, to
assess EMPs that are submitted for review and approval. They will also assist the project
managers, and others involved in developing the EMPs, to understand what DWAFs
minimum requirements are for EMPs in terms of their environmental management policy as
well as the requirements by law.
2.2
Who should use this guideline document
These guidelines are applicable to all DWAF staff, specifically those in the Water Resource
Management branch, who:
develop Terms of Reference for projects;
approve project proposals from consultants;
commission contracts with consultants; and
monitor project implementation.
In addition, these guidelines are designed to assist those parties involved in the project
implementation and operational phases of DWAF Water Resource Management funded
projects. Relevant parties include the:
project planning team;
consulting engineers;
contractors and sub-contractors;
environmental consultants and sub-consultants; and
affected parties.
2.3
Environmental Management Plan guideline structure and contents
This guideline document has been structured in a manner to assist the reader to understand
the background to EMPs and the basis for, developing guidelines for standardised EMPs,
through to understanding what components are required in an EMP.
Chapter One provides an introduction to the EMP guideline project. It includes background
information on Integrated Environmental Management in DWAF as well as the current and
expected legislation requiring the implementation of EMPs. This chapter also explains the
link between this document and the Environmental Management Framework (EMF)
document (DWAF, 2002a), which has been developed to inform and guide DWAF Water
Resources Management Branch with strategic IEM decision-making. A brief explanation of
the activities which will require an EA as expected to be required by the revised Chapter five
of NEMA and the new IEM Regulations.
12
Chapter Two (this chapter) contains document user information to aid effective and efficient
use of the guideline document.
Chapter Three provides generic guidelines for the development of an EMP. It provides a
brief explanation of each of the sections that should be included in the contents of an EMP.
Chapter Four describes the generic impacts with regard to Water Resource Management
projects and activities and the required generic mitigation measures. This chapter also
provides the links to the Register of Environmental Laws Applicable to DWAF (DWAF,
2002c) and to the Environmental Site Management and Rehabilitation Specifications for
DWAF construction sites (ESM&RS) (DWAF, 2002b).
2.4
How to use this guideline document
Chapter One should be read by those requiring an introduction and background to IEM
within DWAF and to EMPs. In addition, readers should consult Chapter 1 if they require a
brief explanation on:
the link between EIAs, EMPs and EMS;
how the EMP fits within the EMF; or
which stage of the project life cycle the EMP is applicable.
Chapter Three is the crux of the document since it provides the guidelines for developing an
EMP as required by DWAF. Readers who require information on the required structure of an
EMP and an explanation of the information required in each section, as well as reasons why
it is required, must consult this chapter.
Readers requiring preliminary information on the probable impacts of the project or activity
and the most probable associated mitigation measure to implement, need to consult Chapter
Four. This chapter also provides a guide as to where in the Register of Environmental
Laws Applicable to DWAF (DWAF, 2002c), a reader may find information on actions
required by DWAF in order to comply with the requirements.
DWAF staff requiring information on the legal requirements of their projects in terms of the
environment must consult the Register of Environmental Laws Applicable to
DWAF(DWAF, 2002c). This register is divided into three sections: Section 1 deals with the
laws other than those administered by DWAF, which may have an influence on activities
undertaken by DWAF in the execution of their statutory mandate, the focus being the
identification of all the issues that are regulated by these laws. Section 2 contains
environmental laws that are not administered by DWAF, but which, by the nature of some of
the Departments activities, could influence such activities. Section 3 comprises brief
discussions of international conventions, common law and legislative developments that may
influence DWAF in the execution of its statutory mandate.
Contractors tendering for DWAF projects must also consult the Environmental Site
Management and Rehabilitation Specifications for DWAF construction sites (ESM&RS)
which were developed in collaboration with this guideline document and which are referred to
in Chapter Four. These ESM&RS and their supporting documentation is available from
DWAF.
13
3.
Generic guidelines
3.1
Who should develop the EMP
The person legally responsible for any consequences related to the environmental management
associated with the project, will, in theory, have the responsibility for the development of the EMP.
While the title of this person differs between projects according to standard DWAF terminology (such
as an Approved Professional Person (APP) for dam construction projects and XYY for other
projects), this document, for ease of reading, will refer to the overall project responsible person as the
project manager.
The project manager may however, not have the capacity (time or qualification), to prepare an EMP.
In such a case, the EMP will need to be prepared by another person within DWAF (in the case of inhouse projects and activities) or the contractors company, or may need to be sub-contracted to an
external party.
Interested and Affected Parties (I&APs), particularly the affected parties, must be given the opportunity
to provide input and to comment on the EMP developed for a project with which they are associated
and by which they may be affected.
They are important contributors to the development,
implementation and eventual success of the plan. Further information on the public participation
process is provided in section 3.3.12.
3.2
Key steps in developing an Environmental Management Plan

Four key steps in developing an EMP:
3.2.1
review available information;

determine the sensitivity of the project;
evaluate impacts and mitigation measures;
and
develop the contents of the EMP.
Review of available information
The initial step in developing an EMP is to review all available information. The type of
information available will be dependent on the nature of the project and its associated
environmental impacts. Information on the following aspects should be reviewed:
nature of the proposed project or activity : For example, if it is a production facility, the raw
materials, the process emissions and effluents and final products involved must be
understood. It is also important to understand the type of project or activity, and its
process, if any. For example, whether it is a new project or an existing activity that is to be
modified. Other factors which must be considered include the extent of the construction
phase; the life expectancy of the project and whether closure and rehabilitation be
considered; and what the type of services will be required for the project such as access
roads, power lines and water pipes;
nature of the receiving environment: The following must be understood:
o
whether the project will take place within a sensitive, undisturbed
environment;
o
whether there are sensitive water systems in the vicinity of the project;
o
whether there are sensitive landscapes or habitats that would be disturbed;
o
whether any threatened species may be affected;
o
what the extent of existing ambient air pollution is; and
o
what the size of the development is; and
perceptions of the interested and affected parties (I&APs): It is important to develop an
understanding of the perceptions of the I&APs regarding the proposed project, whether
14
they are positive, neutral or opposed. It must be determined whether they have been
consulted during the environmental assessment phase and whether their concerns and
issues been addressed.
It is vital to review the environmental assessment that was undertaken with respect to the
proposed project, and to determine whether the potential impacts have been adequately
identified and appropriate mitigation measures prescribed. This is particularly significant as
the mitigation measures form the basis of the EMP. While the EIA reports will provide the
principle source of information, certain projects may have no associated EIA, such as
existing projects and activities. When an EIA has not been conducted, the required
information can be obtained from other reliable sources, which include:
environmental audit reports;
environmental risk assessment reports;
environmental appraisal reports;
environmental management system documentation;
project planning documentation;
permit conditions;
loan agreements;
tender/contract documentation; and
reports from previous studies undertaken on the affected/receiving environment.

Further information could be obtained through a site visit and discussions with I&APs; the
project design team; and the project contractors.
The review of available information provides an important background for the development of
an EMP, but more specifically provides the basis from which to determine the environmental
sensitivity or risk of the project, which is the next step.
3.2.2. Determine the sensitivity of the project
In determining the overall degree of sensitivity of the project, the level of environmental risk
associated with the project is determined. In this context, sensitivity is the combination of:
type and scale of project;
nature and size of potential impacts that would result from the project;
nature of the environment in which the project will take place, (pristine, disturbed
or modified); and
I&APs perceptions regarding the project (positive, neutral or opposed).

It is the level of environmental risk, which ultimately determines the level of detail and
complexity of the EMP. In other words, sensitive projects are high-risk projects that would
require a comprehensive EMP.
Where insufficient information is available to determine the sensitivity of a project and the
overall level of risk, further investigations would need to be conducted. Dependant on the
nature and size of the project, the type of investigation would either follow a formal route of
an EIA for a new project or a due diligence audit for an existing project or activity.
Alternatively, a less formal process of a site inspection and discussions with the design
engineers, other relevant authorities and I&APs may be sufficient.
3.2.3
Assess impacts and mitigation measures
Central to an EMP are the mitigation measures that are necessary to reduce identified
impacts. The basic requirement for the development of an EMP is therefore well thought out,
described and costed mitigation measures. Therefore, the purpose of this step is to
15
determine whether impacts have been adequately identified (either through an EIA, audit,
site visit or other means) and whether the associated mitigation measures are sufficiently
detailed, such that they will reduce the impact to acceptable levels and provide the
necessary detail to enable satisfactory development of the EMP. The requirements of
adequate mitigation measures are discussed further in section 3.3.3.
3.2.4
Develop the contents of the Environmental Management Plan
The EMP must be developed according to whether a mini-EMP or comprehensive EMP is

required for the specific activity or project under consideration. For both these EMPs, all
phases of the life of a project must be addressed. The EMP must document the actions,
procedures and measures required to mitigate and manage environmental risk at all stages
of the project. All relevant design requirements and principles should therefore be captured in
the EMP to avoid any changes from accepted principles during project construction or
implementation.
Development of an EMP is the crux of this guideline document and will therefore not be
elaborated on in this specific section.
3.3
What an Environmental Management Plan should include
There is a wide range of projects and activities for which EMPs are required, and each one
must be tailored to the specific needs of each project or activity and its unique
circumstances. The level and depth of information and resources contained in the EMP must
reflect the level of project-related environmental risk, whilst at the same time remain practical
and achievable. As discussed in section 3.2.2, environmental risk is synonymous with the
degree of sensitivity of a project.
The EMP must document the actions, procedures and measures required to mitigate and
manage environmental risk at all stages of the project. It is thus not a static document but
one that will change and evolve over the life of the project, taking into account not only
changes to the project itself, but also the implications of changing external factors such as
legislation, policy and public and social accountability. Therefore, all EMPs should change
over time, especially those relating to long term projects or activities. Section 3.6 lists the
conditions under which the EMP should be revised.
The initial EMP will be drawn up based on the information from the EA (such as in the EIR),
with the result that it will focus largely on the implementation of mitigation measures.
Subsequent versions of the EMP will be strongly influenced by the results of the performance
assessment, review processes and changes to the project.
For the successful development and implementation of an EMP, the following important
factors must be taken into account:
development of the EMP by a suitably qualified person;

cooperation among project team members and disclosure of information to
appropriate people;
those who develop and implement the EMP must all understand the project and
its potential impacts;
those who develop the EMP must clearly understand and define the scope of the
EMP;
during the development of the EMP use must be made of credible and reliable
information;
attainable and practical goals, objectives and targets must be set in the EMP;
16
the implementing agent (see definition and explanation in Appendix 2) must

ensure adequate financial provisions are made for the effective implementation of
the EMP;
those who develop the EMP must ensure compliance with all legal and regulatory
requirements;
the DWAF project manager (see definition and explanation in Appendix 2) must
ensure that the EMP requirements are stated in relevant legal documents (such
as loan agreements and contract documents) to ensure greater commitment to
the implementation of the EMP;
the required management activities, responsibilities, resources and schedules
must be clearly defined within the EMP;
provision must be made within the EMP, for effective performance assessment
and review cycles; and
I&APs must be involved in the development and implementation of the EMP.
An EMP should be formulated in such a manner that it is user-friendly. The environmental

officer responsible for overseeing the implementation of the EMP should be able to clearly
understand what has to be done, by whom, when and how it should be done. The text of the
EMP must be clear and concise. Technical details should be included in appendices.
Linkages between the EMP and other relevant implementation plans should be clearly
shown, for example plans dealing with the resettlement of people or indigenous people
issues (Davy, 1999).
The minimum requirements for a mini-EMP, for projects with low environmental sensitivity as
expected according to the new IEM Regulations, would be to include:
summary of the negative impacts to be mitigated;
description of the mitigation measures; and
a monitoring programme.
Comprehensive EMPs, ie as expected according to the new IEM Regulations: those for
projects with a high environmental sensitivity, or for projects and activities required by law to
implement a comprehensive EMP, must include the following:
summary of the background information;
summary of the negative impacts to be mitigated;
description of mitigation measures;
summary of the positive impacts that should be enhanced;
description of the actions required to enhance the positive impacts;
cost estimates of mitigation measures;
a monitoring programme;
institutional arrangements: roles and responsibilities, including supervision of the

implementation of the EMP;
training and capacity building required;
public participation process to be followed;
implementation schedule;
environmental awareness process to be followed;
reporting procedures; and
how community upliftment (poverty alleviation) is to be addressed.

3.3.1
Summary of the activity/project background information
In order to place the EMP in context a brief summary should be given of the proposed
development and its associated operational processes involved in both the construction and
operational phases. Since not even those intimately involved with the proposed development
17
are always aware of the various sectors of the environment that will be impacted upon, a
brief description of the affected environment should also be provided. The environment in
this context includes the bio-physical, economic and social components. The above
information would be obtained from the Environmental Impact Report (EIR) and Scoping
Report.
3.3.2
Summary of the negative impacts to be mitigated
The predicted negative impacts for which mitigation is required should be identified and
briefly summarised. Cross-referencing to the EIR from the EIA study is recommended, such
that additional information can be readily found.
This information would be obtained from the Environmental Impact Report (EIR) and Scoping
Report, specifically from the report impact tables.
3.3.3
Description of the mitigation measures
Feasible and cost-effective measures to reduce the severity of potentially significant negative
impacts on the various sectors of the environment, including social, economic and biophysical sectors, must be detailed. Each mitigation measure should be described with
reference to the impact to which it relates, and an indication given as to the conditions under
which is applies (continuously or only in the event of contingencies). The time (such as the
season or time of day) and location of the application of the mitigation measure must be
stipulated in the EMP.
Mitigation measures are aimed at eliminating, offsetting, or reducing adverse environmental
impacts and could have a range of objectives, such as:
avoidance: avoiding projects or activities that could result in adverse impacts.

Avoiding certain types of resources or areas considered to be environmentally
sensitive. This approach is most effective when applied in the earliest stages of
project planning;
prevention: measures aimed at preventing the occurrence of negative
environmental impacts and/or preventing such an occurrence having harmful
environmental and social impacts;
preservation: preventing any future actions that might adversely affect an
environmental resource. This is typically achieved by extending legal protection to
selected resources beyond the immediate needs of the project;
minimisation: limiting or reducing the degree, extent, magnitude or duration of
adverse impacts. This can be achieved by scaling down, relocating, or redesigning
elements of a project;
rehabilitation: repairing or enhancing affected resources, such as natural habitats
or water sources, particularly when previous development has resulted in
significant resource degradation;
restoration: restoring affected resources to an earlier (and possibly more stable
and productive) state, typically a pristine condition; and
compensation: creation, enhancement, or protection of the same type of resource
at another suitable and acceptable location, compensating for lost resources.
Regardless of the objective of a mitigation measure it is important that they are adequately
defined. To determine whether the mitigation measures are adequate they need to satisfy the
following key requirements:
18
written: mitigation measures should be stipulated in writing. This forces the

formulators to think it through carefully;
dated: a mitigation measure must indicate a specific time by when the result must
be achieved;
measurable: mitigation measures must, where possible, be quantitatively defined.
A standard with which performance can be compared, must thus be set; and
understandable: mitigation measures must be described simply, using clear, nontechnical language where possible.
The mitigation measures need to be accompanied by details of the design, equipment,

operating procedures, and technical aspects of implementation.
Where the mitigation measure may result in secondary impacts these should be described
and their significance evaluated.
3.3.4
Performance specifications
The probable performance of the mitigation measures should be assessed and performance
specifications must be specified. Performance specifications are the level to which the
environmental condition must remain or to which it must be improved. A comprehensive list
of environmental performance specifications for construction sites is provided in the
Environmental Site Management and Rehabilitation Specifications for DWAF construction
sites.
3.3.5
Summary of the positive impacts
Often the positive impacts that would occur as a result of an activity or project, are not fully
elaborated upon in the EIR nor in the EMP. These impacts should be listed and described in
a similar manner to the negative impacts. The implications and significance of these impacts
should also be described and evaluated.
3.3.6
Description of the actions required to enhance the positive impacts
The measures required to enhance the positive impacts should be emphasised and detailed
in the EMP. Any possible secondary negative impacts which may occur as a result of these
measures should also be described and their significance carefully evaluated.
3.3.7
Community upliftment measures
An EMP should not only consider mitigation of negative impacts and enhancement of
positive impacts but also consider where further enhancement of affected communities could
be included in the project. These considerations should take place during the project
planning phase and be implemented as part of the EMP. Including such measures in an EMP
would be in alignment with the principle of Equity as required by the National Water Act and
should take the requirements of the Expropriation Act (Act 63 of 1975) into account
Possibilities for such contributions to community upliftment include:
training the local community in skills required for the project, either during the
construction or the operational phase of the project. The advantages of such training
would be enhanced if participants could receive certification for their training for
possible use in obtaining work after the employment on the project is completed;
certain facilities built for use by the project workers could be made available for use
by the community when not in use by the project workers, for example for activities
such as night school;
19
the project proponent could contribute to, facilitate, community activities, for example
through sponsoring local sports clubs or school functions;
training community members in business or financial skills to be able to continue
successful operations once the project has been completed or decommissioned.
This would compensate for the temporary nature of the employment offered by many
projects which have a finite life span;
provision of infrastructure or facilities, other than that directly required for the project.
Some of these measures would require that a percentage (for example 1% of the total
project budget) is made available for their implementation. The amount to be made available
should be suggested during the EA phase of the project and would need to be agreed upon
by the project proponent (DWAF) and would depend on available funds.
Investigation of possible measures to implement and determination of the most suitable
measures will require extensive liaison with team project members, funders/project
proponent, DWAF project team members and affected parties (such as the Local
Municipality). This responsibility would be that of a DWAF staff member in the SES subdirectorate: Social Services.
3.3.8
Cost estimates of mitigation measures
In order for DWAF to understand the implications of the mitigation and enhancement
measures, cost estimates should be specified for both the initial investment and recurring
expenses for implementing the mitigation and enhancement measures contained in the EMP.
The costs of initial and recurring expenses for implementing an EMP should also be included
in the overall project costs. The costs for implementing the measures to contribute towards
local community upliftment should also be included. For certain projects or activities, the
budget should include environmental management contingency funds, which would be
available for the implementation of remedial actions when mitigation measures are not
sufficiently effective or when unanticipated impacts occur.
Recurring expenses include all costs (administrative, design and consultancy, operational
and maintenance costs) associated with meeting specific project criteria.
Where practical, decisions regarding the most appropriate mitigation measures to implement,
should be justified by an economic evaluation of the potential environmental impacts. This
evaluation should:
compare the cost-effectiveness of the different mitigation options;
determine the appropriate level of mitigation where there is scope for a trade-off
between environmental quality and the costs and benefits of achieving it; and
internalise the economic value of residual impacts or intended environmental

improvements into the final economic appraisal of the project (Davy, 1999).
Since the recommended mitigation measures often involve extensive costs, which need to be
borne by the developer or party conducting the activity (DWAF), the costing must be
accurate. The costing should not be done solely by the specialist, who recommended the
measures, but should include the input of an appropriate technical advisor and team
members. The technical advisors must be carefully selected, based on their knowledge of
the mitigation measures being recommended as well as their practical experience in
implementing similar measures and techniques.
DWAF, as the project proponent, and not the environmental authority, is responsible for all
costs that are needed to sufficiently comply with the IEM Regulations. There is a proviso,
however, where the environmental authority may in the case of socially necessary projects
(which may be the case in many of DWAFs proposed projects) elect to bear some or all of
20
the costs associated with compliance with the Regulations or the authority may alter the cost
structure (specifically for government departments).
3.3.9
Description of the monitoring programme
Monitoring is a process of observation, based on specified approaches and schedules, used

to detect whether any changes have occurred in the defined, measurable features of the
particular environment. In other words monitoring detects whether changes have occurred
between an initial or baseline set of data and a follow-up set of data.
An environmental performance monitoring programme is an important part of an EMP, and
should be designed to ensure that the mitigation measures are correctly implemented and
have the desired result. Monitoring in this context refers to repetitive measurement over
time (Hill, 2000). The monitoring programme should consist of thee main aspects:
baseline measuring. This must occur prior to the start of the project or activity in
order to determine the level and status of the environmental parameters prior to
any impacts associated with the project or activity;
impact (or performance) monitoring. This monitoring should be ongoing

throughout the project life-cycle and must be implemented to ensure that
environmental impacts are within the predicted levels; and
compliance monitoring. This monitoring must be implemented to ensure that the

prescribed mitigation measures are having the predicted and desired effect. This
monitoring would be conducted periodically, the timing of which will vary from
project to project. It must be used to check that the levels of specific
environmental parameters are compliant with laws, regulations, standards or
guidelines, as applicable. The programme must make provision for remedial
measures to be effectively implemented in the event of non-compliance, i.e. when
mitigation measures are inadequate or when impacts have been underestimated
in the impact assessment study
Detailed monitoring methods need not be included in the EMP. However, it should include a
description of the means by which final monitoring arrangements will be agreed. The
following aspects should also be included in the monitoring programme:
indication of the linkages between the impacts identified in the EIR;
environmental parameters to be monitored;
indicators to be measured;
mitigation objectives;
targets for optimum performance (minimum environmental impact);
thresholds
monitoring methods to be used;
sampling locations;
frequency of monitoring measurements;
detection limits (where appropriate);
definition of thresholds that will signal the need for corrective action;
responsibility for monitoring;
details of how results will be analysed to determine whether corrective actions are
necessary; and
reporting procedures.
A monitoring strategy must be based on the type of information required for determining
whether objectives and targets are being met. Not all projects or activities, and not all
impacts of any one project, need to be monitored. Monitoring will be necessary and
appropriate, if:
21
there are residual negative impacts that could not be avoided through changes to
project design or reduced through the implementation of other mitigation
measures;
secondary negative impacts arise as a result of the mitigation measures;
there is significant public concern or controversy about an impact;
potential impacts are complex and poorly understood, or if there is disagreement
between the specialists;
the outcome of the recommended mitigation measure(s) is uncertain; or
changes in environmental parameters can be realistically detected.
Assessment of an activity or process will depend on a limited number of important indicators.

It should be remembered that, as the degree of risk associated with a project increases,
more attention must be given to the monitoring process.
3.3.10 Institutional arrangements: roles and responsibilities
Allocating resources and assigning responsibility
The EMP must clearly define the responsibilities for mitigation and monitoring and identify
arrangements for coordination between the various role players responsible for mitigation.
While specific environmental responsibilities are assigned to an environmental officer for
ensuring that the EMP for a specific project or activity is adhered to, the implementation and
monitoring of each mitigation measure may be the responsibility of a different role player.
Some of the required mitigation measures may be the responsibility of DWAF personnel
while others may be the responsibility of their contractors and sub-contractors. These must
be clearly identified in the EMP. For example, responsibilities are assigned to site officers to
ensure that the daily on-site decisions are made in accordance with the EMP. The site officer
may be a DWAF staff member or a contractor, depending on the nature and sensitivity of the
project. A specific person must be assigned the responsibility of acting on the findings of the
monitoring activities.
The responsibilities of DWAF staff are likely to vary depending on the stage of the project
cycle. The responsibilities of contractors and sub-contractors should be translated into
commitments that are legally binding.
Appendix 1 details the different EMP roles and responsibilities of the project role players.
Specifying procedures and practices
The EMP must specify the activities necessary to achieve the mitigation measures and
provide a programme or schedule of the sequence in which the activities will take place and
the time necessary for completing the activities. The EMP must provide a basis against
which implementation can be measured and from which indicators of successful
implementation can be identified.
The EMP should also provide clear guidelines for the determination and implementation of
budgets for all identified activities and set out reporting procedures for implementing these
activities.
Project specific EMPs should include (Hill et al., 1997):
specific work instructions for defining the manner of conducting an activity;
inspection procedures and responsibilities/accountabilities to ensure that

mitigation measures are applied;
procedures for dealing with accidents and emergencies;
22
procedures for measuring performance indicators and interpreting and acting on

the indicators;
records of monitoring data to test the effectiveness of mitigation measures and
impact controls; and
training programmes and evidence of appropriate levels/amounts of
skills/capacities created.
Penalties for Non-Compliance

Section 30 of Chapter five of NEMA proposes penalties for non-compliance with the
provisions of Chapter five. Any person who contravenes the regulations set out here or
commits an offence as described in this section is liable for a fine or jail term. The
responsible person or even the minister within the DWAF who is undertaking an activity that
contravenes these regulations, will be liable for these penalties.
3.3.11 Training and capacity building requirements
The trend towards increased public awareness and participation in the EIA process will
require that the proponents of developments meet rigorous environmental standards and
make provision for personal liability and financial assurance for their environmental
performance. An EMP can ensure good environmental performance, improved
communication relations, reduced costs and lower risk of legal liability.
Training is essential for ensuring that the EMP provisions are implemented efficiently and
effectively. Training needs should be identified based on the available and existing capacity
of site and project personnel (of both DWAF and the contractors team) to undertake the
required EMP mitigation implementation and monitoring activities (refer also to section four of
the ESM & RS (DWAF, 2002b). It is vital that all personnel are adequately trained to perform
their designated tasks to an acceptable standard. Training requirements must be identified
and must be clearly specified as part of the EMP requirements.
3.3.12 Public participation process to be followed
Prior to finalising an EMP, all people affected by the project or activity should be consulted.
This consultation should help in the design of achievable mitigation measures. This is
particularly true where the success of the mitigation measure depends on the buy-in or
actions of the public. A guide to public participation, a generic process and methods to use
for public participation, are provided and discussed in the Generic Public Participation
Guidelines published by DWAF (2001). The process followed and the degree of public
participation will vary between projects depending on the dynamics of the project. An
example where no public participation will occur is in the case of Emergency Works, and this
is due to the obvious time constraints in carrying out the works/project.
Public participation assists to focus the EMP on those aspects of social and environmental
risk that can cause costly delays later on. The public consultation for an EMP should be
reasonable but not exhaustive. All the affected parties (and not necessarily the interested
parties) must be provided with an opportunity to provide input into the development of the
EMP. For projects and activities where the impact assessment was done with appropriate
public participation, an EMP would normally follow without further specific consultation
around the EMP with I&APs. The EMP should be developed in conjunction with the EA to
obtain comment on the EMP at the same time. The issues that were raised during public
participation either by the public, the technical specialists, the proponent or the authorities,
and the mitigation measures to manage such issues, need to be clearly reflected in the EMP.
Keeping this in mind at the start of the process reduces the risk of process failures and costly
delays for stakeholders and the authorities later on. In those cases where an EMP needs to
23
be developed for a project, but no EIA has been done, affected parties need to contribute to
the development of the EMP. The issues of concern and suggestions for enhanced benefits
need to be obtained during the initial stages of drafting the EMP. This will ensure that the
EMP addresses those aspects of the operation that could be a source of social risk.
Once the EMP has been drafted, the process of providing information (in non-technical
language) in regard to the contents of the EMP, and obtaining comment on the draft, needs
to be repeated. Stakeholders should verify that their issues of concern have been
considered in the document, and have opportunity to ask questions on the proposed
mitigation and management measures. It is also advisable to submit the draft EMP to
DWAF, in the case of sub-contracted projects, and other relevant authorities (such as the
provincial DEAT department) for their review and comment before finalisation of the
document.
Once the project or activity has begun, the affected public should be provided with
information on the progress with the implementation of the mitigation and monitoring
measures. This could be provided in newsletters, on on-site notice boards, or at public
meetings.
A source of social risk is to discontinue the involvement of stakeholders subsequent to the
public participation process for the EMP. Relationships forged between DWAF and
stakeholders during the initial processes need to be maintained, although not always at the
same level of intensity. Affected Parties need to feel and understand that their safety, health
and environment are not being compromised. They should be kept informed (for example via
newsletters and notices) so that no uncertainty exists, for example during the period between
the EA being complete and site establishment.
3.3.13 Implementation schedule
The timing, frequency and duration of mitigation measures should be specified in an
implementation schedule. This schedule should show the links with the overall project
implementation plan. Where the implementation of mitigation measures is tied to the project
legal agreement, these linkages should be outlined. For example, where successful
implementation of a mitigation measure is a condition for payment by DWAF. This schedule
should form part of a contract and be measurable with the contractor being subject to
penalties for late implementation.
3.3.14 Environmental awareness process to be followed
In addition to training, general environmental awareness must be fostered among the
projects workforce to encourage the implementation of environmentally sound practices
throughout its duration.
Environmental awareness and training is an important aspect of the implementation of the
EMP. The onus is on the different parties involved in the various stages of the life cycle of the
project to be environmentally conscious. Hence, it is suggested that all members of the
project team are familiar with the findings of the site-specific EA report and the EMP. For
instance, the contractor is responsible for the lack of environmental knowledge of his/her
crewmembers. The contractor could forward internal environmental awareness and training
procedures to the project manager and environmental officer for comment prior to the
commencement of the project. Likewise, the above is applicable to the planning, design,
operations and maintenance, and decommissioning teams. Environmental awareness
ensures that environmental accidents are minimized and environmental compliance
maximized.
24
3.3.15 Documentation, record keeping and reporting procedures

It is vital that an appropriate document handling and retrieval system be developed for all
EMP documentation. This will ensure that there is adequate EMP documentation control and
will facilitate easy document access and evaluation. EMP documentation should include:
EMP implementation activity specifications;
training records;
site inspection reports;
monitoring reports; and
auditing reports.
Responsibilities must be assigned to relevant personnel for ensuring that the EMP
documentation system is maintained and that document control is ensured through access
by, and distribution to, identified personnel.
Document control is important for the effective functioning of an EMP. A document handling
system must be established to ensure adequate control of updating and availability of all
documents required for the effective functioning of the EMP. This procedure applies to the
EMP as well as procedures and policies relating to the EMP, which must be controlled (i.e.
identified, registered and changes recorded).
The Environmental Officer is responsible for ensuring that the registration and updating of all
relevant EMP documentation is carried out. It is the responsibility of the Project Manager to
ensure that all personnel are performing according to the requirements of this procedure and
to initiate the revision of controlled documents, when required by changes in process,
operating procedures, legislation, specifications, audit findings or any other circumstances,
by informing the Environmental Officer of the changes. A controlled document is official only
if the issue/revision has been approved. The Environmental Officer and Project Manager are
responsible for ensuring that the latest versions of documents are used to conduct tasks
which may impact on the project environment.
The EMP and procedure documents must be controlled and only distributed according to a
distribution list compiled by the Environmental Officer. Documents should be numbered and
controlled according to the distribution list. These documents shall be marked controlled
copy. Holders of controlled documents shall sign the distribution list when they receive a
new or revised document and must destroy the old version. Whole documents should not be
reprinted and older versions destroyed when only a few pages are affected by the revision.
Documents must be revised as required by changing circumstances. Any user of a controlled
document can initiate a proposed change to a document by submitting a memo to the
responsible person for further attention. The responsible person will present the change
proposal to the Environmental Officer or Project Manager for authorisation. Once authorised,
the document will be officially changed and distributed. All changes must be recorded on the
official document change control sheet attached to each document. Obsolete documents will
be removed and destroyed except for those retained for legal and knowledge-preservation
purposes, in which case the document must be marked, obsolete/retained. After an incident
that impacted negatively on the environment or caused an injury, procedures will be revised
as required if it is found that the existing procedures are inadequate.
Distribution lists and document change control sheets must be kept for all documents.
Records must be kept for at least five years.
Reporting procedures for conveying information from the monitoring activities must be
developed in order to ensure that management is able to take rapid corrective action should
25
certain thresholds be exceeded. Reporting procedures and format should be the same for all
DWAF projects and activities.
3.4
Auditing the implementation of an Environmental Management Plan
Auditing is a process to evaluate compliance with stipulated EMP requirements and to

assess the achievement of defined objectives and targets. The timing of the audits should
be included in the implementation schedule in the EMP.
An audit analyses the results obtained from monitoring, assesses whether objectives and
targets have been met and whether there are variances from the stipulated EMP and legal
requirements. In addition, the audit also assesses whether EMP implementation has been
undertaken according to planned arrangements and that the EMP itself is being appropriately
updated. The audit should confirm that the identified corrective action has been undertaken
and then assess the effectiveness of that action.
The key steps in a successful audit are:
establish audit procedures;
determine the frequency of audits;
ensure that the auditors are competent, in that they must be able to undertake the
audit objectively and competently. Audits may be undertaken by internal or
external parties, although certain I&AP requirements may define a need for
external auditors; and
maintain records of audits.

A procedure should be developed for conducting EMP audits, incorporating processes for
scheduling, conducting and reporting. This procedure should also address responsibilities
and required resources. Table 3.1 presents an example of an audit procedure together with
a description of the type of information that should be included. The objective of the audit
procedure is to ensure that formal audits of the EMP are scheduled and performed so as to
verify compliance with the requirements of the EMP.
The Environmental Manager, or a person authorised and appointed by him/her, is
responsible for the maintenance of the Environmental Audit System. The Environmental
Manager is responsible for the scheduling and execution of the audit, as well as the
verification of the implementation of corrective action. At his/her discretion, this authority may
be delegated to responsible DWAF personnel, or to an independent Environmental Auditing
Authority to perform the audit on his/her behalf.
Auditors shall have no direct responsibility in the area/system being audited. They will be
trained in techniques for auditing environmental systems.
The project manager responsible for an area/system to be audited (or a responsible person
nominated by him/her) will assist the audit team in the execution of the audit. The divisional
manager will also be responsible for timely corrective actions based on the findings of the
audit.
26
Table 3.1:
An example of an audit procedure. This procedure describes the sequence of

events required to perform a compliance audit and the verification of
implemented corrective action.
Planning the audit
The Environmental Officer, or his/her authorised delegate, shall plan the

audit of a particular environmental area or system as follows:
he/she shall inform, in writing, the division to be audited of the
intention to conduct an audit at least two weeks prior to the audit. This
notification should include the audit objective, scope and duration and
any assistance required from the division.
on completion of the audit, an audit findings sheet shall be prepared
and submitted to company senior management as well as to the
division which was audited.
corrective actions shall be implemented, within eight weeks after the
audit, where possible.
Audit schedule
The environmental audits will be scheduled annually.
Audit check list
Auditing will be performed by collecting evidence for verification through

interviews, relevant documentation and observation of activities and
conditions. Instances of non-conformity to EMP criteria should be
recorded. An environmental audit checklist can be used as a guide to
address all relevant issues.
Audit findings and

reporting of noncompliances
The audit team shall review all evidence of their audit findings to decide on
non-compliance. Audit findings of non-compliance must be documented
and supported by evidence in the Audit Findings Report.
The non-compliance findings will be communicated to the Environmental
Officer and his/her representatives during an audit feedback meeting.
The Environmental Officer, or person responsible for corrective action, will
sign the audit findings report sheet to indicate acceptance and
commitment to the required corrective action.
Once the corrective action has been implemented, the area/system will be
re-audited by the same person who recorded the non-compliance (where
possible, to ensure uniformity). The Environmental Officer will co-ordinate
this audit.
Once the corrective action has been successfully implemented, the
verification sections of the audit findings sheet must be completed and
signed off.
Records
Completed copies of all documents referred to in this procedure shall be

kept by the Environmental Officer for a period of at least five years.
Changes to this procedure will be recorded on the document change
control sheet.
3.5
Translation of EMP requirements into tender documents for sub-consultants
Stipulating the requirement for an EMP may ensure its satisfactory development, but does
not guarantee its implementation. It is therefore important to ensure that the actions specified
by the EMP are enforced through the EMP being given some form of legal standing. This can
be achieved through incorporating the EMP as an addendum to the tender documents for a
particular project and specifying under the special conditions of contract for the tender that
27
the requirements of the EMP apply and must be met. This will ensure that obligations are
clearly communicated to contractors and that submitted tenders have taken into account, and
budgeted for, the environmental requirements specified in the EMP. The successful tender
ultimately becomes the signed contract, thereby ensuring that the included EMP has legal
bearing.
DWAF could use environmental criteria in tender documents as a basis for selecting subcontractors. Construction contracts should include specifications on environmental
performance and bills of quantities for mitigation measures and monitoring, including
personnel, equipment and analyses (Hill, 2000). Contractors should also be obliged to follow
appropriate environmental, health and safety standards to reduce associated risk during
construction and operation of a project. The ESM & RS (DWAF, 2002b) must be included in
contracts with contractors.
In cases where the EMP cannot, for whatever reason, be included in the tender document,
the EMP requirements should be included as a change or variation order to the contract.
Similarly, any alterations to the EMP should also be included as a change or variation order
to the contract.
3.6
Conditions under which the Environmental Management Plan should be revised
The initial EMP will be drawn up based on the information in the EIR, with the result that it
will focus largely on the implementation of mitigation measures. Subsequent versions of the
EMP will be strongly influenced by the results of the performance assessment and review
processes.
EMPs should be dynamic, flexible and subject to periodic review (Hill, 2000). The extent to
which EMPs should be reviewed will vary depending on the project or activity. Where the
major negative impacts are associated with the construction phase, the EMP may require no,
or limited, revision. For projects where the major environmental impacts are associated with
the operational phase, the EMP may require regular review and subsequent revision. In part,
this is linked to the influence of changes in legislation, such as the current revision of NEMA
and the development of the new IEM Regulations.
Conditions under which the EMP will require revision include:
changes in legislation;
occurrence of unanticipated impacts or impacts of greater significance, intensity

and extent than predicted;
inadequate mitigation measures, i.e. where the level of an environmental

parameter is not conforming to the required level despite the implementation of
the mitigation measure; and
secondary impacts occur as a result of the mitigation measures.

Senior management responsible for a project, including the DWAF project manager,
contractor and environmental officer should conduct a review of the EMP and its
implementation to ensure that the EMP remains effective and appropriate.
The management review should:
i)
Review :
o environmental objectives, targets and environmental performance;
o effectiveness of the EMP based on the findings of previous monitoring
reports and EMP audits;
ii) Evaluate the need for changes to the EMP as required by:
o the findings of the review;
28
iii)
iv)
v)
o changing legislation;
o changing expectations and requirements of affected parties;
o changes in activities;
o lessons learnt from incidents; and
o changes to environmental standards
Verify the effectiveness of corrective action;
Determine the root cause(s) of deficiencies; and
Develop a plan to address root causes.
Where potential problems or non-compliance are identified, these may be addressed by

either stipulating corrective or preventative action or modifying the EMP.
3.7
Consideration of departmental documentation during the development and

implementation of an Environmental Management Plan
Any document for implementation by, or on behalf of, DWAF cannot be developed or
implemented in isolation of other relevant departmental documentation. If this occurs, conflict
or contradicting actions may arise. Examples of such DWAF documentation which must be
taken into account when implementing an EMP for dam construction and maintenance
include the Sustainable Utilization Plan and the Zoning Plan. Both these plans address the
management of the water surface and adjoining area.
29
4.
Generic impacts and the associated generic mitigation measures for

DWAF Water Resource Management projects
4.1
Introduction
This chapter provides a brief description of the most common generic impacts resulting from
most of the DWAF Water Resource Management projects and activities and a description of
the associated generic mitigation measures. Both the impacts on the biophysical (Table 4.1 )
and the social (Table 4.2) aspects of the environment are provided. In these tables, the link
to the Environmental Laws Applicable to DWAF (DWAF, 2002c) and to the Environmental
Site Management and Rehabilitation Specifications for DWAF construction sites (ESM&RS),
are also provided. These lists of impacts and mitigation measures are not exhaustive but are
provided as a guide to assist those involved in developing, or reviewing, an EMP, to
understand which issues should be addressed as a minimum requirement.
30
Table 4.1:
Generic biophysical impacts and associated generic mitigation measures. (The link to the ESM&RS refers to Table 2.2,
which deals with General Environmental Works. Readers should also refer the specific table(s) in the ESM&RS of particular
relevance to the activity to be undertaken.)
Impact
Project phase
Mitigation measures
Legal register,
Section 1, reference
(sub-section) number
Section to refer to in
ESM&RS (Table 2.2)
for applicable
Performance
specifications
Soil:
Loss of topsoil (the
essential substrate for
plant growth and hence
rehabilitation);
Erosion;
Compaction and crusting;
Changes in soil properties
(eg acidification and
salinisation);
Chemical contamination;
Invasion of exotic biota.
Pre-construction;
Construction;
Operation
a) Prior to earthmoving operations all topsoil (top 300mm as a

minimum) must be stripped and stockpiled separately from
subsoil and rocky material. Soil must be stripped in a phased
manner so as to retain vegetation cover for as long as possible.
F2 - F5;
H3;
H8;
H 10
Site establishment;
Access roads;
Combat erosion;
Vegetation clearance;
Topsoil;
Erosion control;
Slope protection;
Storage;
Pollution prevention;
b) Stockpiled topsoil should not be compacted and should be

replaced as the final soil layer. No vehicles may be allowed
access onto the stockpiles after they have been placed.
c) Stockpiled soil must be protected by erosion-control berms if
exposed for a period of greater than 14 days during the wet
season.
d) To prevent topsoil from being spread out or mixed with the
other spoil during the construction, soil stockpiles must not take
the form of windrows.
e) Topsoil stripped from different sites must be stockpiled
separately and clearly identified as such.
f)
Topsoil obtained from sites with different soil types must not be
mixed.
g) Topsoil stockpiles must not be contaminated with oil, diesel,

petrol, waste or any other foreign matter, which may inhibit the
later growth of vegetation and micro-organisms in the soil.
h) Soil must not be stockpiled on drainage lines or near
31
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
watercourses.
i)
Soil must be exposed for the minimum time possible once

cleared of invasive vegetation. The timing of clearing and
grubbing should be co-ordinated as much as possible to avoid
prolonged exposure of soils to wind and water erosion.
j)
Stockpiled topsoil must be either vegetated with indigenous

grasses or covered with a suitable fabric to prevent erosion and
invasion by weeds.
k) To limit the introduction of alien species into the area, no soil

may be imported onto site without notifying the environmental
officer.
l)
Seasonally wet areas and/or turf soils to be avoided during wet

and rainy periods or while the soil is drenched.
m) Only light equipment may be used for transport and delivery of

construction material in areas of unstable soils, in areas where
no erosion is evident and at river and stream embankments.
n) Only limited vehicular access is allowed across rocky outcrops
and ridges.
o) All cut and fill surfaces need to be stabilized with appropriate
material or measures when major civil works are complete.
p) Erosion and donga crossings must be dealt with as river
crossings. Appropriate soil erosion and control procedures
must be applied to all embankments that are disturbed and
destabilized.
q) All equipment to be inspected daily for oil or fuel leaks before it
32
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
B5
B6;
C2;
C3;
D1;
D2;
D4;
D8;
D9;
D10;
F7;
F8;
H3;
H8;
Site establishment;
Erosion control;
Water quality
monitoring;
Offices & other
structures;
Storage;
Pollution prevention;
is operated. Leakages must be repaired on mobile equipment

or containment trays placed underneath immobile equipment
until such leakage has been repaired.
r)
Soil contaminated with oil must:

be dug up to 30 cm below the saturated oil mark; or
disposed at a permitted landfill site; or
the soil can be regenerated using bio-remediation methods.
s) Reduce runoff by channelling water into a surface drainage

system.
t)
Water:
Altered hydrology ;
Contamination of water
resources;
Sedimentation;
Salinisation;
Eutrophication of rivers or
impoundments
Ground water
contamination;
Surface water pollution;
Barriers to migration of
fish, aquatic vertebrates
Construction;
Operation;
Near vertical slopes (I1:1 or 1:2) must be stabilised using hard

structures following specifications, preferably with a natural look
and facilities for plants to grown in. Areas with a 1:3 1:6 slope
must be logged or stepped secured logs must be placed in
continuous lines following the contours and spaced
appropriately depending on the steepness of the slope.
a) Adequate sedimentation control measures must be instituted at

any river crossings when excavations or disturbance of
riverbanks or riverbeds takes place.
b) Adequate sedimentation control measures must be enforced
where excavations or disturbance of drainage lines of a wetland
may take place.
c) The batching plant must be positioned away from drainage
lines, and measures to ensure that no polluted water enters a
natural stream , i.e more than 20m from the nearest stream /
river channel.
d) All runoff from batching areas must be strictly controlled.
33
Impact
fish, aquatic vertebrates

and invertebrates;
Invasion of alien invasive
plants reduction in
quality and quantity of
water;
Invasion of alien invasive
animals through
intercatchment
connections;
Wetland loss through
drainage or reduced
inflow;
Wetland pollution.
Project phase
Mitigation measures
Legal register,
Cement contaminated water must be collected, stored and

disposed of at a site approved by the Site Engineer.
ESM&RS (Table 2.2)
for applicable
Performance
specifications
H10
e) Appropriate measures for overflow from batching plant, e.g

during heavy rains, must be put in place.
f) The batching plant shall be bunded with earth berms or
sandbags to prevent runoff escaping from the site.
g) Waste concrete and cement sludge must be scraped off the
site of the batching plant daily and removed to an approved
landfill site. (To prevent pollution during the rain).
h) Concrete shall not be mixed directly on the ground.
liners or mixing trays are to be used.
Plastic
i)
All fuel, chemical, oil, etc spills must be confined to areas where
the drainage of water can be controlled. Use appropriate
structures and methods to confine spillages such as the
construction of berms and pans, or through the application of
surface treatments that neutralise the toxic effects prior to the
entry into a water course
j)
Oil absorbent fibres must be used to contain oil spilt in water.
k) During construction through a wetland, the majority of the flow

of the wetland should be allowed to pass down stream. Instream diversions should be used rather than the construction
of new channels.
l)
Vehicle traffic across wetland areas must be avoided.
m) No dumping of foreign material in streams, rivers and/or

wetland areas is allowed.
34
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
n) A wetland area and/or river must not be drained, filled or altered

in any way including alteration of a bed and/or, banks, without
prior consent from DWAF and the relevant DEAT office. The
necessary licenses must be obtained from DWAF in terms of
Section 21 and 22 of the National Water Act, (Act 36 of 1998).
o) No fires or open flames are allowed in the vicinity of the
wetland, especially during the dry season.
p) Wetlands should not be disturbed and should be allowed to
function normally.
q) No swimming, washing (including vehicles and equipment),
fishing or related activity is permitted in a wetland or river
without written permission from the Environmental officer.
r)
The Contractor must install and maintain mobile toilets at work

sites.
s) No storm water must be allowed to enter drainage installations

(ie installations for the reception, conveyance, storage or
treatment of sewage.
t)
Maintain soil erosion structures such as stone pitching, gabions,

etc to enable effectiveness.
u) The Contractor must provide adequate and approved facilities

for the storage and recycling of used oil and contaminated
hydrocarbons. Such facilities must be designed and situated
with the intention of preventing pollution of the surrounding area
and environment.
v) All vehicles must be serviced in the designated area within the
Contractors camp.
35
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
F1 F9;
H3;
H8;
H10
Site establishment;
Access roads;
Planting;
Fencing & gates;
Destumping;
Landscape
rehabilitation;
w) All chemical spills must be contained and cleaned up by the

supplier or professional pollution control personnel.
Flora:
Loss of individuals of rare
or endangered species;
Damage to the integrity of
the ecosystem functioning;
Heavier utilization of
medicinal and /or
protected plants;
Invasion of alien
vegetation.
Construction
a) All suitable and rare flora and seeds must be rescued and
removed from the site. They must be stored at a suitable
location/nursery, for future use in rehabilitation.
b) Protected plants must be tagged, and they must not be cut or
damaged in any way. Likewise, alien vegetation will also be
tagged during the site-specific investigation, however such
vegetation must be destroyed by the Contractor (see (e) below).
c) The felling and/or cutting of trees and clearing of bush must be
minimised.
d) Bush must only be cleared to provide essential access for
construction purposes or as directed by the contractors
representative.
e) Where alien invasive plants occur they must be uprooted, cut
and/or chemically treated. (Use only approved chemicals). The
contractors representative must only appoint a registered weed
control officer to chemically treat any invader species. Care
must be taken to avoid the spread of seeds of alien vegetation.
f)
Where wetlands will be disturbed or lost through construction,

large sods of soil material containing plant material must be
transplanted in such a way as to inoculate the new wetland
created on site or used for nursery storage and multiplication.
g) Any incident of unauthorised removal of plant material, as well

as accidental damage to priority plants, must be documented by
36
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
the contractors representative.

h) All complaints relating to damage to or destruction o flora must
be reported to the EA for further investigation.
i)
j)
Transplanting of small trees (1 to 1,5 m height) and small

shrubs (0,5 to 1 m height)
Trees and shrubs must only be transplanted between the

months April and September. Deciduous trees and shrubs
must be transplanted only when they are in a leafless
condition.
Holes for transplanting trees and shrubs must be dug

before these plants are dug out. Trees must be planted in
holes of 1 x 1 x 1 m or larger and shrubs must be
transplanted in holes of 600 x 600 x 600 mm or larger.
Trees and shrubs must be planted so that their stems or

trunks are at the same depth as in their original location.
The orientation of the transplanted plants must be the same
as in their original location (i.e. if taken from a north-facing
slope the plant must be replanted on a north-facing slope).
Transplanted plants must be pruned to limit transpiration.

Plants must also be sprayed with an evapo-transpiration
retardant liquid if they are evergreen.
Transplanted plants must be watered once a week for 5

weeks and thereafter once every 2 weeks.
Transplanting of Aloes and Bulbous Plants
37
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
Aloes and evergreen bulbous plants may be

transplanted at any time of the year. Deciduous
bulbous plants must be marked when in leaf and
transplanted when they are leafless.
j)
Aloes and bulbous plants must be planted in similar soil

conditions and to the same depth as they were before
removal.
Transplanted aloes and bulbs must be watered once

directly after transplanting to settle the soil.
Woody vegetative matter stripped during construction must

either be spread randomly throughout the surrounding veld so
as to provide biomass for other micro-organisms and habitats
for small mammals and birds, or it may be stockpiled for later
redistribution over the reinstated topsoiled surface.
No
vegetative matter must be burnt or removed for firewood other
than those removed during the grubbing and clearing phase.
Such vegetation can be made available to the local inhabitants
to be used as firewood.
k) No tree outside the footprint of the Works area may be

damaged.
l)
If any protected tree, identified in the site specific study, is

felled, cut, pruned and/or, in the opinion of the environmental
officer, is unduly damaged by the Contractor, the Contractor will
pay a penalty (amount stipulated by DWAF) per tree (as a
minimum) or the market value for the replacement of the tree,
which ever is the greater.
m) Trees selected for preservation in the site-specific study within
38
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
F1 F9;
H3;
H8;
H10
Site establishment;
Protection of fauna;
or adjacent to the Works areas must be fenced around their

drip line. The fence must be clearly marked with danger tape.
No open fires may be lit within this fenced area.
Fauna:
Loss of individuals of rare
or endangered species;
Disturbance of fauna (eg
disrupted breeding of fish
in dammed areas, and
disturbed bird nesting
areas);
Construction
Operation
a) No species of animal may be poached, snared, hunted,

captured or wilfully damaged or destroyed.
b) Fishing is only allowed with the written consent of the
landowner and only when anglers are in possession of a
Provincial Fishing License.
c) Snakes and other reptiles that may be encountered on the
construction site must not be killed unless the animal
endangers the life of an employee.
d) Anthills that occur must not be disturbed unless it is
unavoidable for construction purposes.
e) Any incidents of poaching wilful disturbance or damage to wild
animals, as well as accidental damage to or death of wild
animals must be recorded by the CR and made available to the
EA on a weekly basis. Any complaints about damage to or
destruction of fauna must be investigated the CR.
f)
Nesting sites of birds must not be disturbed.
g) The contractors representative and environmental officer must

ensure compliance with the relevant Nature Conservation
Ordinances.
h) The contractors representative must ensure that the work site
is kept clean and free from rubbish, which could attract pests.
i)
The contractors representative must ensure that domestic and

native animals belonging to the Local Community are kept away
39
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
A1 A6;
H3;
H8;
H10
Access roads;
Dust control;
Fire control
from unprotected works.

j)
All animals injured on account of construction activities must be

taken to the local SPCA. Dead animals must be disposed at a
permitted landfill site.
k) No pesticides must be used unless approved by the

environmental officer, and may only be applied by an approved
specialist.
l) No game may be purchased or sold under any circumstances.

m) If water is dammed, an ichthyologist must be consulted, during
the site-specific study, to establish the impact on the breeding
patterns of the affected fish species.
The contractors
representative and environmental officer must ensure
compliance with the findings of the investigation.
n) Particular care must be taken to avoid nesting, breeding and
roaming sites of animals in or adjacent to wetland areas.
Air:
Dust;
Odours exhaust fumes;

waste material; smoke.
Construction;
Operation
a) Speed limits must be enforced in all areas, including public

roads and private property to limit the levels of dust pollution.
b) Dust must be suppressed on access roads and construction
sites during dry periods by the regular application of water or a
biodegradable soil stabilisation agent. Water used for this
purpose must be used in quantities that will not result in the
generation of turn-off.
c) Suitable screening and containment measures must be in place
40
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
to prevent wind blown contamination.

d) The site-specific investigation must quantify the impact of dust
on nearby wetlands, rivers and dams in terms of sedimentation.
All mitigation measures identified during the site specific study
must be implemented.
e) The contractors representative or environmental officer must
notify all people living within 50m of the construction site of
proposed activities.
f)
An operational water cart must be permanently available onsite.
g) The contractors representative or environmental officer must

notify the Principal of all schools within 50m of the site of
proposed activities. The Principal must in turn ensure that
children with allergies and respiratory ailments take the
necessary precautionary measures during the construction
period. Construction activities must not disturb school activities
e.g. dust clouds may reduce visibility affecting sports activities.
h) In the event of serious levels of dust pollution, the
implementation of constant dust monitoring by qualified
consultants must be undertaken.
i)
Waste must be disposed, as soon as possible at a municipal

transfer station, skip or on a permitted landfill site. Waste must
not be allowed to stand on site to decay, resulting in malodours
and attracting vermin.
j)
The contractors representative or environmental officer must

inform all adjacent landowners of any after-hour construction
activities and any other activity that could cause a nuisance e.g.
41
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
E1;
H3;
H8:
H10
Noise control;
Blasting
the application of chemicals to the work surface. Normal

working hours is between 07h00 and 17h00 Monday to Friday.
Arrangements are to be made with the Local Authority for afterhours work.
k) The contractors representative or environmental officer must
ensure that all on-site vehicles comply with the SABS 0181
standards.
l)
No random cooking fires are to be allowed on site except

designated cooking areas.
m) Vehicles used on, or entering, the site must be serviced

regularly to ensure that they do not emit smoke or fumes.
Noise
Construction
a)
Noise control measures must be implemented. All noise levels

must be controlled at the source. If the noise levels at the
boundaries of the site exceed 7 dB above ambient levels, the
local health authorities must be informed. All employees must
be given the necessary ear protection gear.
b)
Affected parties must be informed of the excessive noise

factors.
c)
Pumps must be housed in a brick building to help reduce any

noises when the pump is in operation.
d)
Affected livestock farmers must be informed of noisy activities a

month in advance. This will enable them to take appropriate
steps to prevent disturbance and possible injury to livestock e.g.
moving the livestock to distant camps.
e)
The relevant by-laws and regulations (as highlighted in the sitespecific investigations) must be adhered to. Noise control is
42
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
B1;
B2;
F2;
F3;
F4;
H3;
H8;
H10
Access roads;
Combat erosion;
Slope protection;
Shaping and trimming;
Aesthetics;
Offices & other
structures;
Blasting;
Landscape
rehabilitation;
specific investigations) must be adhered to. Noise control is

regulated by the Environmental Conservation Act, 73 of 1989,
Occupational Health and Safety Act, 85 of 1993 and provincial
and local by-laws.
Aesthetics:
Reduced sense of place and
hence tourism potential of the
affected area;
Reduced visual integrity
Construction;
Operation
f)
Noise mufflers and/or soft explosives must be used during

blasting to minimise the impact on humans and animals.
g)
No loud music is allowed on site and in construction camps.
a) Damage to the natural environment must be minimized.

b) Trees and tall woody shrubs must be protected from damage to
provide a natural visual shield. Excavated material must not be
placed on such plants and movement across them must not be
allowed, as far as practical.
c) The clearing of sites must be kept to a minimum and
surrounding vegetation must, as far as possible, be left intact as
a natural shield.
d)
At construction sites in densely vegetated areas, the vegetation

must be cut at angles of 45 degrees from the bottom to
minimise any visual impact.
e) No painting or marking of natural features must be allowed.

Marking for surveying and other purposes must only be done
with pegs and beacons.
f)
All above ground structures must be treated or painted to blend

in with the natural environment and every endeavour must be
made to cover as much as possible of exposed structures.
43
Impact
Project phase
Mitigation measures
g)
Use shade cloth for areas that are exposed to the public,
particularly near busy roads.
h)
After closure of the batching plant, all waste concrete / cement

shall be removed together with contaminated soil. The surface
will then be ripped to a depth of 150mm and the top soil
replaced evenly over the site and regressed .
i)
Where existing access routes and borrow pits have been

overgrown with vegetation such surfaces must not be graded.
Selective cutting of trees and shrubs to allow access of not
wider than four meters must take place.
j)
Cut and fill areas, river and stream crossings and other soil
stabilisation works must be constructed to blend in with the
natural environment. Natural rocks from the environment must,
as far as possible be used for such stabilisation works provided,
the removal of such rocks does not constitute an offence or
results in a negative impact on the environment. Such activities
should not cause major river diversions or alter the banks of the
river, in which case a license will be required.
k)
Borrow pits must be shaped to have undulating slopes and

surfaces such that they blend into the natural landscape as
much as possible.
l)
Blasted areas and cut and fill slopes must be as rough as

possible such that (i) the natural surroundings are emulated as
far as possible and (ii) the jagged ledges facilitate the
accumulation of soil and the subsequent establishment of
vegetation.
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
m) Where possible, concreted surfaces on embankments and

storm water gullies must be undulated to minimise surface
44
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
reflection.
n)
Natural outcrops, rocky ridges and other natural linear features,

must not be bisected. Vegetation on such features must, as far
as possible, not be cut unless necessary for construction.
Written approval must be obtained form the environmental
officer for such operations.
o)
Excavated material must be flattened (not compacted) or

removed from site. No heaps of spoil material must be left on
site once the Contractor has moved to a new construction site.
p)
Any complaints from interest groups regarding the appearance

of the construction site must be recorded and addressed
promptly by the environmental officer and contractors
representative.
q)
Littering on site and the surrounding areas is prohibited.

Clearly marked litterbins must be provided on site.
The
contractors representative must monitor the presence of litter
on the work sites as well as the construction campsite. All bins
must be closed to prevent refuse from being blown out by wind.
All bins must be cleaned of litter on a daily basis. Large skips
must be stored in a fenced area. Encourage waste separation.
r)
All waste removed from site must be disposed at a

municipal/permitted waste disposal site.
s)
Excess concrete, building rubble or other material must be

disposed of in areas designated specifically for this purpose and
not indiscriminately over the construction site.
t)
The entire works area and all construction sites must be swept
of all pieces of wire, metal, wood or other material foreign to the
45
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
G1
G2;
H10
Site establishment;
Fencing & gates;
natural environment.
u)
All plastic material must be removed form area where livestock

could swallow it.
v)
Contaminated soil must be treated and disposed at a permitted

waste disposal site, or be removed and the area rehabilitated
immediately.
w) Waste must be recycled wherever possible.

Disturbance of archaeological
sites
Construction
a) Work in areas where artefacts are found must cease

immediately. The EO must be notified immediately and a
Global Positions System reading must be taken.
b) The excavation must be examined by an archaeologist as soon
as possible. The EA will advise the Contractor of necessary
actions to be taken after receiving advice from the
archaeologist. All necessary actions to ensure that delays are
minimised must be taken.
c) Under no circumstances must the contractor, his employees,
his sub-contractors employees remove, destroy or interfere
with archaeological artefacts.
Any person who causes
intentional damage to archaeological or historical sites or
artefacts could be penalised or legally prosecuted in terms of
the National Heritage Resources Act (Act 25 of 1999).
d) A three-strand fence 2m outside the extremities of the site must
be erected to protect archaeological sites. The fence must be
clearly marked with danger tape. Vehicular traffic must not be
allowed on archaeological and historical sites, within a 5m
radius from the perimeter of the site.
46
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
e) All known and identified archaeological and historical sites must

be left untouched. No stones or rocks must be removed from
such sites. These rocks must not be painted, whitewashed or
similarly treated.
f)
The contractors representative must ensure that employees do

not gain access to any archaeological areas (whether fenced or
unfenced), except when authorised to do so by the
environmental officer.
47
Table 4.2:
Generic socio-economic impacts and associated generic mitigation measures. (The link to the ESM&RS refers to Table 2.2,
which deals with General Environmental Works. Readers should also refer the specific table(s) in the ESM&RS of particular
relevance to the activity to be undertaken.)
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
Relocation of homesteads or
communities (applicable to
larger projects such as dams
construction)
Planning;
Construction
a) Owners of Land to be expropriated must receive compensation

in terms of the Expropriation Act, Act 63 of 1975;
G1;
G2;
H1;
H2;
H3;
H7;
H8
Site establishment
b) Undertake extensive public participation, allowing a decision

making process that is based on rights and risks culminating in
negotiated outcomes;
c) Negotiation of project specific agreements, for example those
relating to benefit sharing, resettlement and compensation;
d) Project must be planned in consultation with local community
leaders;
e) Advance planning of Compensation programme;
f)
Resettlement Action Plan and development programmes for the

displaced must be planned in advance. This must be done in
accordance with the S&ES standard Resettlement Action Plan;
g) If required, provision of temporary accommodation must be

planned in advance;
h) Ongoing liaison with community leaders / representatives must
be maintained in order to track any problems with the
relocation;
i)
Affected people must be empowerment to participate effectively

in the process.
48
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
Direct or indirect loss of

essential resources, such as
fishing rights,
Construction;
Operation
a) The amount of essential resources lost must be minimised

through alternative project design;
G1;
G2
Site establishment
b)
Alternatives to compensate for lost resources must be found;
c)
Damage to crops
compensated for.
H2;
H3;
H7;
H8
Disturbance of graves
Planning and
Construction
or
other
food
resources
must
be
a) Any graves situated in the construction site or area of

inundation in case of dams, must be dealt with according to the
Exhumation Laws of the Provincial Government and with the
bye-laws of the Local Municipal Authority.
b)
If a graveyard is discovered, the EO must be contacted

immediately.
The relatives of the deceased must be
contacted immediately. The local chief, SAHRA and Local
Authority must also be informed of the situation.
c)
Where possible and feasible, minor re-routing of

infrastructures, such as pipelines, must occur so as to avoid
disruption of graves.
d)
The relatives must be informed should a grave need to be

moved. The exhumation of bodies must be executed in the
local traditional manner and affected families allowed
sufficient time to perform any traditional rituals.
e)
Grouping of graves ( for example, according to families)

must be retained in the new layout.).
f)
All finds of human remains must be reported to the nearest

police station to ascertain if there was any crime involved.
H2;
H3;
H7;
H8
Site establishment;
49
Impact
Project phase
Mitigation measures
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
Expectations regarding
employment opportunities will
abound and will need
monitoring
Preconstruction;
Construction;
Operation
a)
Extensive public participation at all stages of the development

from planning through implementation must take place.
G1;
G2;
H9
Site establishment
b)
Advance projection of the socio-economic impacts of the

project must be provided to the public.
c)
Information on
disseminated.
d)
A Community Liaison Officer must be employed to act as

information broker regarding the project
G1;
G2
Site establishment
C2;
C3;
C4;
C5;
H110;
H11;
H12
Accidents;
Increased security risks for Construction;

the affected parties (local Operation
residents)
the
proposed
project
must
be
widely
a) Construction camp must be planned with detail. Such that

affected parties do not feel threatened by the presence of
construction workers.
b) If possible, local labour must be employed to avoid the need to
construct a camp for imported labour.
Injury to workers and public
Construction;
Operation
a) Best practice methods must always be employed and

appropriate Regulations adhered to, for example when blasting.
b) No open trenches should be permitted without the use of
demarcation tape.
c) Speed limits must be enforced in all areas, including public
roads and private property to avoid potential accidents.
d) There must be a first aid facility on site.
e) Advance warning of blasting activities.
50
Impact
Project phase
Mitigation measures
f)
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
Erection of scaffolding must be undertaken by a certified

practitioner.
g) Regular auditing of safety requirements must be undertaken in

order to monitor and control problems before they become
unmanageable.
h) A safety and health officer must be employed to monitor project
activities for any potential problems
i)
Workers right to refuse work in unsafe conditions must be

respected
j)
A record must be kept of all incidents on site.
k) Personnel must be trained in basic site safety procedures.

l)
Secure storage of materials on site particularly hazardous

materials e.g chemicals and fuels.
m) Adequate signage on and off site about potential hazards must

be provided.
Increased spread of HIV Aids

in the areas surrounding the
project site
Construction;
Operation
a) An AIDS awareness programme must be provided for all

project workers
Ssite establishment
b) Condoms should be supplied at health facility / First AID centre

and at all strategic areas.
c) Recreational facilities for project workers, particularly those
resident at the construction camp, must be provided.
51
Impact
Project phase
Mitigation measures
Employment prospects and

other economic spin-offs
Planning;
Construction;
Operation
a)
The project must be planned, as far as is appropriate, in

consultation with local authorities and aligned with local plans
such as IDPs
b)
Labour intensive methods must be used where feasible, cost

effective and not time constraining.
d)
Local labour must be employed as far as is practical.
e)
Training of the unskilled must be undertaken.
f)
Local suppliers must be used, as far as possible.
Disruption of Services: e.g

road access, water and
electricity, etc
Construction
a) Where service disruption is inevitable, the Contractor must

advise the Project Manger at least 7 days in advance, allowing
enough time to inform affected parties.
b)
Legal register,
ESM&RS (Table 2.2)
for applicable
Performance
specifications
Site establishment
Services installation;
A complaints register must be maintained on site.
c) Updated information boards must be maintained on site and

must include contact details for complaints by the public in
accordance with details provided by the Engineer.
Informal traders:
Planning;
Construction
a) Plan for informal traders on the construction site to avoid

potential problems on site.
Site establishment
b) Access to the site must be controlled.

c) Signs prohibiting other hawkers from operating illegally on /
adjacent to the site must be erected. This is important if
construction area is near a busy road, for example.
52
5.
References
Davy, A. 1999. Environmental Management Plans. The World Bank Update report number
25.
Department of Environmental Affairs and Tourism, South Africa. April 1998. EIA Regulations.
Implementation of Sections 21, 22 and 26 of the Environment Conservation Act.
Department of Water Affairs and Forestry. Generic Public Participation Guidelines.
September 2001.
Department of Water Affairs and Forestry. Consolidated Environmental Implementation and
Management Plan. 14 December 2001. Government gazette 22929. Government Printer,
Pretoria.
Department of Water Affairs and Forestry. 2002a. Environmental Management Framework.
Department of Water Affairs and Forestry. 2002b. Environmental Site Management and
Rehabilitation Specifications for DWAF construction sites.
Department of Water Affairs and Forestry 2002c. Register of Environmental Laws Applicable
to the Department of Water Affairs and Forestry as at 31 December 2001. Report to DWAF.
Hill R.C., Bowen P.A., and Soboil J.H. 1997. The role of environmental management
systems in construction. Australian Institute of Building Papers 8: 27-39.
Hill, R.C. 2000. Integrated Environmental Management Systems in the implementation of
projects. South African Journal of Science 96: 50-54.
Pero, L.V. 2001. Discussion Document: Towards Practice Guidelines for the Effective
Incorporation of EMSs and EMPs as Part of EIAs. CSIR Report ENV-P-I 2000-061.
Republic of South Africa 1998. National Environmental Management Act (Act 107 of 1998).
Government Gazette 401 (19519). Government Printer, Pretoria.
Suter. G.W. (Ed). 1993. Ecological Risk Assessment. Lewis Publishers, Michigan.
Swaziland Environmental Authority. June 1999. Environmental Audit, Assessment and
Review Guideline.
53
Appendix 1: Environmental Management Plan roles and responsibilities

To ensure efficient and effective EMP implementation, roles and responsibilities should be
assigned to all EMP parties, including the:
DWAF personnel;
appropriate environmental authority;
environmental officer;
site engineer;
all contractors; and
general public
DWAF must appoint a project manager (the APP or
) to represent the Department
and must ensure that the scope of work of the project manager includes environmental
supervision. The EA must give direct feedback to the project manager regarding all
environmental matters. All decisions regarding environmental procedures and protocol must
be approved by the project manager, who also has the authority to stop any construction
activity in contravention of the document.
DWAF is responsible for the maintenance, update and review of the EMP.
1.
Implementing agent, project manager and environmental advisor
The person or organisation that will implement the project or activity is the Implementing
Agent. When the activity is an in-house DWAF activity or project, the implementing agent
would be DWAF itself, for example the Directorate: Social and Environmental Services.
When the project is contracted out by DWAF, the implementing agent would be the
contractor.
1.1
Implementing Agent
The implementing agent is responsible for the implementation of the EMP, however, the
liability associated with non-compliance rests with DWAF. Hence, the Department must
ensure that environmental compliance is clearly defined in the Terms of Reference for the
contractor. A permanent environmental advisor should be employed by DWAF or the
contractor for the duration of the project. The environmental advisor should be well versed
in environmental studies. The contractor is answerable to the environmental advisor for noncompliance with the requirements stated in the EMP.
1.2
Project manager
DWAF must appoint a project manager to represent the Department and must ensure that
the scope of work of the project manager includes environmental supervision. The
implementing agent is answerable to the project manager for all environmental issues
associated with the project and the environmental advisor must give direct feedback to the
project manager regarding all environmental matters. All decisions regarding environmental
procedures and protocol must be approved by the project manager, who also has the
authority to stop any construction activity in contravention of the document.
1.3
Environmental Advisor / (ECO?)
The environmental advisor will liaise between the Department and the contractor, consulting
engineer, independent environmental consultant, operations and maintenance manager,
commissioning manager and decommissioning manager, on all environmental concerns.
DWAF is responsible for the maintenance, update and review of the EMP. All modifications
to the EMP must be communicated to the relevant parties through the environmental advisor.
54
The environmental advisor will compile a monitoring and auditing plan to ensure that the
environmental management measures are implemented and are effective. The aim of such
plan is to develop a cost effective environmental performance monitoring procedure. The
environmental advisor is also responsible for monitoring the performance of the contractors
representative; issuing of site instructions to the contractor for non-listed activities; and
assisting in the resolution of conflicts.
2.
Contractors Representative
The contractor should appoint a contractors representative, who is responsible for the on-site
implementation of the EMP. The contractors representative can be the site agent; site
engineer; a dedicated environmental officer; or an independent consultant. The contractor
must ensure that the contractors representative is suitably qualified to perform the necessary
tasks and is appointed at a level such that she/he can interact effectively with other site
contractors, labourers, the environmental advisor and the public. As such the contractors
representative must:
know the background of the project, and monitor the implementation of the EMP;
ensure continuous auditing of the project for adherence to the document,

identification of problem areas and provision of action plans to avoid costly
stoppages and/or further environmental damage;
ensure transparent and open communication for reporting significant environmental

incidents to the relevant authorities and the EA. Inform the EA of the incident within
24 hours of the occurrence and maintain a photographic record where necessary;
ensure that all complaints and concerns from the public and other Interested and
Affected Parties (I&APs) are resolved and addressed immediately;
establish a liaison, co-ordination and reporting framework involving I&APs
conduct regular site audits during the construction phase and subsequent phases.
submit compliance reports to the environmental advisor at the stipulated frequency;

and
ensure that the development site is cleared and rehabilitation by the contractor
according to the specifications as set out in this document.
3.
Consulting Engineer
For many of the DWAF projects a consulting engineer may be appointed. The consulting
engineer is involved with the planning and design phase of the project and must ensure that
the requirements of the EMP are enforced during these phases. The consulting engineer
must also ensure constant consultation with the independent environmental consultant and
environmental advisor.
4.
Independent Environmental Consultant
An independent environmental consultant may be appointed on certain projects, such

as........................and would be responsible for:
ensuring compliance with the environmental requirements of the EMP;
ensuring complete compliance with the EIA regulations for listed activities;
reporting all environmental incidences to the environmental advisor;
ensuring compliance with all conditions of the Record of Decision;
completing the Environmental Compliance Checklist (for listed activities);
giving site instructions to the contractor, when it is stated in the record of decision
that the contractor must be monitored, and
liaison with the environmental advisor on all environmental issues.
55
5.
Operations and Maintenance manager
The operations and maintenance manager and/or his/her representative is responsible for
the on-site implementation of the EMP during the operational phase of the project and are
answerable to the environmental advisor for non-compliance. The operations and
maintenance manager has the same degree of responsibilities in terms of this EMP as the
contractor and the contractors representative.
56

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GUIDELINES FOR STANDARDISED

ENVIRONMENTAL MANAGEMENT PLANS

Department of Water Affairs and Forestry

Acronyms and abbreviations

Approved Professional Person

Corrective (or remedial) Action

USERS GUIDE ..............................................................................................................12

BACKGROUND TO INTEGRATED ENVIRONMENTAL MANAGEMENT IN DWAF............1

GENERIC GUIDELINES ..............................................................................................14

GENERIC IMPACTS AND THE ASSOCIATED GENERIC MITIGATION

An example of an audit procedure.

Generic biophysical impacts and associated generic mitigation measures.

Generic socio-economic impacts and associated generic mitigation measures.

Background to Integrated Environmental Management in DWAF

Background to the development of the guideline document

What is an Environmental Management Plan?

define the actions needed to implement these measures;

describe how this will be achieved; and

ensuring compliance with regulatory authority stipulations which may be local,

verifying environmental performance through information on impacts as they occur;

responding to changes in project implementation not considered in the EIA;

responding to unforeseen events; and

providing feedback for continual improvement in environmental performance.

The role of Environmental Management Plans within Integrated Environmental

implementation and in this regard deals with responsibilities, resources and

FEASIBILITY & RE- APPRAISAL

PRE-FEASIILITY & RE- APPRAISAL

CLOSURE & DECOMMISIONING

EMP implementation &

Linking Environmental Assessment, Environmental Management Plans and

Environmental Management Plans and the South African environmental

Sections 11 and 15 of NEMA impose an obligation on DWAF to develop an environmental

Legislation requiring the development of project Environmental Management

investigation of mitigation measures to keep adverse impacts to a minimum, as well

investigation and formulation of arrangements for the monitoring and management of

Land use policies,

Terms of Reference for

Environmental Authority Review

Environmental Authorisation subject

The process expected to be required in the new IEM Regulations.

NEMA principles to guide the development of Environmental Management

Development must be socially, environmentally and economically sustainable.

Environmental management must be integrated, acknowledging that all elements of

Environmental justice must be pursued so that adverse environmental impacts shall

Equitable access to environmental resources, benefits and services to meet basic

Responsibility for the environmental health and safety consequences of a policy,

The participation of all interested and affected parties in environmental governance

Community well-being and empowerment must be promoted through environmental

The social, economic and environmental impacts of activities, including

Decisions must be taken in an open and transparent manner, and access to

There must be intergovernmental co-ordination and harmonisation of policies,

Actual or potential conflicts of interest between organs of state should be resolved

Global and international responsibilities relating to the environment must be

The costs of remedying pollution, environmental degradation and consequent

Sensitive, vulnerable, highly dynamic or stressed ecosystems, such as coastal

According to Section 28 of NEMA, whenever a DWAF activity, function or project causes,

by law), the pollution/degradation must be minimized and rectified. Examples of reasonable

Activities that Require Environmental Assessment by law

National Water Act