The local engineering industry is increasingly undertaking a mass-balance approach for its production and environmental impacts, where it analyses resources at source or input level, calculates the outputs and weighs the difference against the impact reduction costs, states consulting engineering firm GIBB.
“In several instances, the costs of mitigating environmental impacts at production output level is more expensive than at the source level, as best practices at the output level, or greener technology changes, might imply and require significant infrastructure changes that could increase a company’s capital expenditure (capex),” says GIBB GM and director Dr Urishanie Govender.
Better-quality input material limits the amount of output material generated, which, in turn, limits the changes and additional environmental requirements industry need to comply with, adds environmental licensing unit senior environmental scientist Tashriq Naicker.
He points out that the fines and penalties industry can face for environmental noncompliance include criminal and civil sanctions, including personal liability for directors.
Govender notes that the current penalties for environmental crimes are cited in a suite of environmental legislation under the framework of the National Environmental Management (Nema) Act and its associated legislation. Depending on the offence committed, penalties can range from 5 to 10 years imprisonment and/or fines of between R5-million and R10-million or both.
Industry also needs to use a balanced approach when embarking on further development, GIBB sustainability manager Karien Erasmus adds, pointing out that, for example, the GIBB Sustainability Aspire Model, which is a strategic sustainability assessment approach, considers the environmental risks and the socioeconomic impacts, in addition to the financial benefits of the development
“This model will enable companies to apply a holistic and strategic perspective, identify the possible environmental risks and plan accordingly, which will result in cost effectiveness, time savings and environmental compliance,” she says.
Govender agrees, adding that, while capex spend was dedicated to increase output in previous years, capex currently needs to be committed to environmental protection, owing to changes to Nema, and the shortened and phased timeframes for environmental impact assessment (EIA) submissions and authorisations that are expected to be introduced in 2015.
As industry faces limited timeframes for the environmental submissions and applications, companies need to be more aware of the environmental authorisation requirements and, more importantly, obtain environmental expertise early in the project life cycle, such as at feasibility stage, to ensure that the necessary requirements are included as part of the scope of the project, Govender says.
Naicker adds that promulgation of the Infrastructure Bill, this year, to support the National Development Plan and the Presidential Infrastructure Coordinating Commission’s 18 Strategic Integrated Projects (SIPs), necessitated changes in environmental regulations to streamline environmental authorisations, as EIAs are one of the first requirements before the design, construction and procurement of new projects.
Further, GIBB has taken note of the plans to streamline the different environmental Acts and integrate the different processes, Naicker says, adding that the Nema, first promulgated in 1998, provides for integrated decision-making.
“This streamlining will eliminate disparity in issuing the different approvals that often result in project delays, and which could have significant impacts, particularly on the SIPs,” Naicker says.
Despite increased focus on environmental management, Govender notes that a key industry challenge includes industry’s awareness of the requirements and timeframes for environmental authorisations.
She explains that consultants are often appointed to a project and provide the clients or companies with the EIA and environmental authorisation timelines, with the expectation that the initial research for alternatives, cleaner production best practices and basic layout designs for the project have been completed.
“However, when this information is not available at the required time, it results in delays in the environmental authorisation processes, which further delays projects or new operations.”
Naicker agrees, further pointing out that when companies do not provide the required information according to the EIA regulations, the authorisation results received from the various authorities might not be relevant, as the authorisation is not technically or financially feasible for the company to implement.
Up to now industry’s environmental authorisation regime has been of a fragmented and complex nature, as Acts, such as the National Water Act, the National Environmental Management: Protected Areas Act, the National Heritage Resources Act, the National Environmental Management: Waste Act and National Environmental Management: Air Quality Act, each have different mandated authorities responsible for authorisations, GIBB Environmental Licencing Unit manager Elisabeth Nortje says.
Therefore, proactive planning to streamline the processes should be a key focus for companies that need environmental authorisation for new projects or expansions, she emphasises.
Industry should be made aware that, while the EIA and Nema regulations, sustainability reporting and best practices are to limit environmental impacts, they are not to limit development, Erasmus says.
“These legislations and practices are to assist and enhance the opportunities of development in the economy,” Erasmus concludes.