Article Critique

Benchmarking the effectiveness of mitigation measures to the quality of environmental impact statements: lessons and insights from mines along the Great Dyke of Zimbabwe

Patrick Gwimbi1 • Godwell Nhamo2

Received: 9 November 2014 / Accepted: 11 April 2015 / Published online: 19 April 2015 � Springer Science+Business Media Dordrecht 2015

Abstract The environmental impact statement (EIS) plays an important role in informing decision makers about the likely impacts of development projects on the environment and

suggesting mitigation measures for addressing such impacts. Increased effort to improve

the quality of EIS has been a focus on its proposed mitigation measures and their likely

effectiveness. There is, however, a lack of such studies in Zimbabwe’s mining industry.

Following a conceptual framework of EIS quality as an indicator of mitigation effec-

tiveness, this paper assesses the quality of EIS and its likely influence on the effectiveness

of its proposed mitigation measures. Twenty-two purposively sampled EISs for mines

operating along the Great Dyke of Zimbabwe were reviewed using the modified Lee and

Colley (Review of the quality of environmental statements, Manchester EIA Centre,

University of Manchester, Manchester 1992) quality review package and Mitchell’s (EA

the Magazine of IEA and EARA 28–29, 1997) mitigation hierarchy guidelines. Results

show that 77 % of the EISs are of satisfactory quality, while 51 % of the proposed

mitigation measures focus on adverse impact reduction. The deficiencies are traced to

vagueness in the regulations regarding baseline data collection and analysis and concep-

tualization of mitigation. Based on the results, it is suggested that more efforts should be

aimed at reviewing the EIA regulations in order to improve the quality of EISs.

Keywords Environmental impact statement � Review area � Environmental impact assessment � Mining � Great Dyke � Effectiveness � Mitigation � Zimbabwe

& Patrick Gwimbi pgwimbi@yahoo.com

Godwell Nhamo nhamog@unisa.ac.za

1 Department of Environmental Health, National University of Lesotho, Maseru, Lesotho

2 Institute for Corporate Citizenship, University of South Africa (UNISA), Pretoria, South Africa

123

Environ Dev Sustain (2016) 18:527–546 DOI 10.1007/s10668-015-9663-9

1 Introduction

The quality of environmental impact statement (EIS) is often used as a major indicator of

environmental impact assessment (EIA) effectiveness (Morrison-Saunders et al. 2001;

Sadler 1996). As a technical document, the EIS provides mitigation measures which ad-

dress adverse impacts of project development activities and enhance the quality of human

health through its influence on decision making (Glasson et al. 2005; Canelas et al. 2005;

Evans 2013). The evaluation of EIS is therefore very important to validate its information

and likely effectiveness in protecting the environment from development activities (Okafor

2008; Sok 2014). However, while several studies have been carried out at international

level on the quality of EISs (Pinho et al. 2007; Sandham et al. 2008; Kabir et al. 2010),

there is paucity of such information in Zimbabwe. This paper arose from an attempt to fill

this gap.

Mitigation is a key review area in EIS and lies at the heart of EIA (Wood 2003). The

argument in the literature is that it is the role of EIS to relay its proposed mitigation

measures in an accurate and understandable manner in order for informed decisions to be

taken (Pinho et al. 2007; Sandham et al. 2008; Kabir et al. 2010). Pinho et al. (2007)

argument is that, the effectiveness of mitigation measures is inextricably linked to the

quality of EIS. This assertion is supported by Ortolano and Shepherd (1995) and Wende

(2002), whose analysis of the impact of EIS quality on EIA effectiveness shows that there

is a clear relationship between the two. According to Ortolano and Shepherd (1995), EIS

illuminates environmental issues to be considered in making decisions and provides signs

that make it known with a reasonable degree of certainty the effectiveness of such

decisions.

In Zimbabwe, Part XI (99) (d) of the Environmental Management Act (Chapter 20:27),

which became obligatory in 2003, requires project proponents with development projects

likely to adversely impact on the environment to:

Specify the measures proposed for eliminating, reducing or mitigating any an-

ticipated adverse effects the project may have on the environment, identifying ways

of monitoring and managing the environmental effects of the project (Government of

Zimbabwe (GOZ) 2003: 391).

The regulations require project proponents to produce detailed EISs on the environ-

mental impacts of the proposed actions, its alternatives, and any available mitigation

measures. Since the inception of the regulations in 2003, development projects such as

mines have carried out EIAs and suggested mitigation measures to address the identified

impacts. Yet, while such provisions are a welcome reflection of a desire to promote

environmental sustainability within the mining industry, an evaluation of the quality of

EISs to examine how well the proposed mitigation measures are working is nonexistent.

The works of Ravengai et al. (2005a), Makore and Zano (2012) and Meck (2013)

demonstrate that mining activities continue to adversely impact on the environment despite

such projects being subjected to EIA studies as required by the law.

To address this gap, this paper evaluated the quality of EISs for selected mines oper-

ating along the Great Dyke of Zimbabwe as a potential indicator of the effectiveness of

mitigation measures proposed during EIA. Based on the literature review, a framework of

EIS quality as indicator of mitigation effectiveness in EIA was developed. The framework

discusses EIS review areas that drive mitigation effectiveness in EIA.

528 P. Gwimbi, G. Nhamo

123

2 Conceptual framework: quality of EIS as an indicator of mitigation effectiveness

The EIS is considered the technical heart of the EIA process (Sok 2014). As the main

mechanism through which EIA information is reported and accessed, its quality is regarded

as critical to the effectiveness of its proposed mitigation measures (Barker and Jones 2013).

Environmental impact assessment (EIA) effectiveness is defined as the degree to which

EIA is successful in meeting its objectives and purpose (Peterson 2010). Sadler (1996: 37)

defines effectiveness as ‘‘how well something works or whether it works as intended and

meets the purposes for which it is designed.’’ The objectives and purpose of mitigation in

EIA are stated as influencing decision making and contributing to sustainable development

(Glasson et al. 2005). Sadler (1996) divides effectiveness into three categories: procedural,

substantive, and transactive. Procedural effectiveness assesses the degree of compliance

with established regulations, standards, and guidelines (Morrison-Saunders and Bailey

2009). Substantive effectiveness focuses on the achievement of the set objectives, while

transactive effectiveness is achieved where the outcomes are obtained with least cost in the

minimum time frame (Glasson et al. 2005). Theophilou et al. (2010) suggest that sub-

stantive effectiveness is demonstrated through changes to the project plan or program

being assessed in order to realize the goals of EIA.

The ability of EIA in meeting its objectives and purpose depends on several interlinked

factors (Peterson 2010). In this framework, the quality of EIS as an indicator of mitigation

effectiveness is addressed. Conceptualizing EIS quality as an indicator of mitigation ef-

fectiveness is intended for determining the extent to which EIS influences decision making,

based on its quality. Mitigation measures proposed in EIS are considered the foundation

(Marshall 2001) or heart (Wood 2003) of EIA.

The fact that the EIS is the primary and most important tangible source of information

decision makers are provided with to make informed decisions is not debatable (Polonen

2006). The document contains information that informs decision makers and the public

about the environmental consequences of the project and facilitates appropriate measures

that can be used to mitigate the identified impacts. What is debatable, though, is the quality

of information in EIS and its appropriateness in facilitating better decisions (Lee et al.

1999; Tinker et al. 2005; Polonen 2006). According to Lee et al. (1999: 35) ‘‘it is the

appropriateness and quality, and not the volume of information provided which is the

relevant consideration.’’

The types of mitigations listed in EISs should be in order of their desirability for

addressing adverse effects. According to Mitchell (1997), mitigation refers to measures

used to avoid, minimize, repair, and compensate adverse impacts, and enhance positive

impacts of project development activities, in that hierarchical order. In a preferential sense,

avoidance is considered more desirable and compensation least desirable (Tinker et al.

2005). In Hayes and Morrison-Saunders view (2007), every effort should be made to

suggest avoidance measures first, then minimize, and only then compensate the damage as

the last resort. Perceived this way, avoidance actions are perceived to result in an envi-

ronmental quality outcome the same as the baseline environmental condition and com-

pensation the least (Marshall 2001; Tinker et al. 2005). This approach has been adopted by

many regulators internationally when approving or rejecting EISs for different projects

submitted by project proponents for funding (Hayes and Morrison-Saunders 2007). The

existence a hierarchy of mitigation measures, however, also suggests that all impacts

cannot be avoided in reality (Marshall 2001).

Benchmarking the effectiveness of mitigation measures to the quality… 529

123

In order to assess the effectiveness of mitigation measures proposed in EIS, a baseline

of EIA practice is essential (Sandham et al. 2005). Understanding baseline data sets the

benchmark for judging the effectiveness of implemented mitigation measures during

monitoring (Kubo et al. 2009). Mitigation measures are also emphasized in the EIA pro-

cess once the extent of the potential impacts is well understood.

3 Methodology

The study methodology was based on content analysis of EIA regulations and EISs for

selected mining projects along the Great Dyke of Zimbabwe. The EISs were reviewed

focusing on baseline information, impact identification and evaluation, and alternatives and

types of mitigation measures proposed. The modified Lee and Colley (1992) review

package and Mitchell’s (1997) mitigation hierarchy guidelines were used to review the

quality of EISs and types of mitigation measures, respectively. The two packages are used

worldwide, and the results obtained using them can be compared to other similar studies in

different countries.

3.1 Study area

The EISs investigated were for mines operating along the Great Dyke of Zimbabwe (Fig. 1),

a mineral rich belt spanning about 550 km long and 4–11 km wide (Makore and Zano 2012).

The Great Dyke was selected for four main reasons. Firstly, it contains significant quantities

of mineral deposits, including: platinum group of metals (PGMs), chrome, gold, nickel,

asbestos, magnetite, and copper that are under exploitation (Chakupa 2011).

Secondly, based on its mineral abundance, the majority of mine EIAs have been un-

dertaken along the Great Dyke. Thirdly, many mining activities impact negatively on the

environment despite such projects being subjected to EIA studies as required by the law

(Meck et al. 2006). The study provided a unique opportunity to assess the quality of such

EISs and their influence on the effectiveness of its proposed mitigation measures. A study

of this nature could shed some light on the barriers to the quality of produced EISs and the

challenges to the likely effectiveness of the proposed mitigation measures. Lastly, the

Great Dyke is dominated by both large and small-scale mining activities (Makore and Zano

Fig. 1 Platinum mines operating along the Great Dyke

530 P. Gwimbi, G. Nhamo

123

2012). Hence, the Great Dyke offered the opportunity to review the quality of EIS for both

large- and small-scale mines. Figure 1 shows the location of two EISs focusing on large-

scale platinum-smelting plant and mine used in this study: Selous Metallurgical Complex

platinum-smelting plant and Ngezi platinum mine.

3.2 Selecting the EIS sample

Access to EISs was first sought from the Environmental Management Agency (EMA)

library, but these were considered confidential and inaccessible to third parties such as

researchers. On that basis, it was not possible to establish the EIS population along the

Great Dyke for the review period. The study then relied on EISs provided by consenting

project proponents and EMA-registered EIA consultants.

A purposive sample was made for the review. Purposively, EISs reviewed were for

mines and carried out between 2003 and 2010. The year 2003 is when EIA became a legal

requirement, while 2010 gave time lag for judging whether implemented mitigation

measures were effective, another issue not covered in this paper. Project proponents were

purposively sampled from telephone directory for the area under review. It was empha-

sized to consenting sources that the required EISs were for mines located along the Great

Dyke, similar to those submitted and approved by EMA and carried out between 2003 and

2010. EMA-registered consultants were purposively sampled on the basis of whether they

carried EIAs for any mine along the Great Dyke.

A total of 36 EISs, similar to those approved by the Zimbabwe’s Environmental

Management Agency, were obtained for review. Out of the 36 submitted EISs, 13 were

carried out after 2010 and therefore considered ineligible for review according to the set

criteria. One EIS had some missing pages and was therefore excluded. In total, a sample of

22 EISs was selected for review. The EIS sample size used compared well with previous

samples used elsewhere. Androulidakis and Karakassis (2006) for example reviewed a total

of 37 EISs when evaluating the quality of EISs in Greece, while Nadeem and Hameed

(2006) reviewed four in Pakistan and Sandham et al. (2008) assessed 20 EISs for mines in

South Africa.

3.3 Conducting the EISs review

Before embarking on a review of the sampled EISs, the country’s EIA regulations were

reviewed in order to determine whether the regulatory requirements were followed. In

Zimbabwe, the EIA legislation dictates the review sections that should be included in EISs.

A description of the regulations and key review areas to be discussed in the EISs provided

the foundation for examining some of the factors influencing the quality of reviewed EISs.

The EISs review focused on three review areas: baseline, impact identification and

evaluation, and alternatives and mitigation. The baseline information reviewed included

physical, biological, and social environments before project development activities com-

menced. This provided the basis for judging on whether the proposed mitigation measures

were effective or not by comparing baseline data with monitoring data after development

activities commenced.

Impact identification and evaluation review area was in terms of definition of impacts,

impact identification methods, and assessment of impact significance, as prescribed in the

Lee and Colley (1992) EIS quality review package.

The third stage pertained to reviewing the alternatives, mitigation measures, and

monitoring.

Benchmarking the effectiveness of mitigation measures to the quality… 531

123

Figure 2 shows the schematic diagram of how the review was carried out. The review

process commenced at the sub-categories level. Each sub-category was appraised and

assigned an assessment symbol. The assessment symbols assigned to the sub-categories

were then used to appraise each of the review categories until the overall assessment was

completed (Table 1).

Each review was graded from A to F, with A being of the highest standard and F being

very unsatisfactory. The better the grade of each reviewed area, the higher the quality of

the EIS; and in the context of mitigation measures, the more effective they were presumed

to be in practice. The general threshold between a passable EIS and a noncompliant one

was grade C.

The Lee and Colley (1992) EIS quality review package suggests that two reviewers

assess each EIS in order to avoid bias during evaluation (Lee et al. 1999). The independent

reviewers meet to discuss any differences of opinion before integrating their reviews into

one based on consensus. Peterson (2010) concurs with this approach, arguing that pair

assessment is more critical than individual assessment. For this study, it was, however, not

possible to have two independent reviewers. However, to minimize bias, three EISs were

repeatedly reviewed at a day interval by the researcher, and the results were compared to

the previous ones following the approach previously used by Bond and McGrath (1997).

The approach entails re-reviewing the same EIS after some time and then comparing the

results with those of previous reviews. Bond and McGrath (1997) used this approach in

their previous studies and noted that the results were similar.

Seeking to examine the types of mitigation measures proposed in the EISs, Mitchell’s

(1997) mitigation guidelines form (Table 2) was used. Mitigation measures proposed in

EISs were classified into any of the five types ‘‘avoid,’’ ‘‘reduce,’’ ‘‘repair,’’ ‘‘compensate,’’

and ‘‘enhance’’ (Mitchell 1997).

Fig. 2 Adapted hierarchical structure of the Lee and Colley (1992) EIS review package. Source Adapted from Lee and Colley (1992)

532 P. Gwimbi, G. Nhamo

123

4 Results

The overall distribution of the reviewed EISs by year of production is shown in Fig. 3. The

sizes of EISs ranged between 56 and 152 pages. The two EISs focusing on large-scale

mining sites had the highest number of pages, 152 on average.

4.1 EISs legislative provisions

In Zimbabwe, the Environmental Management Act (chapter 20:27) requires project pro-

ponents to produce EISs prior to undertaking development projects affecting the quality of

environment.

Fig. 3 EISs reviewed by year of submission

Table 1 Grade symbols for assessing EIS quality using the Lee and Colley review package

Symbol Explanation

A Relevant tasks well performed, no important tasks left incomplete

B Generally satisfactory and complete, only minor omissions and inadequacies

C Can be considered just satisfactory despite omissions and/or inadequacies

D Can be considered just satisfactory despite omissions and/or inadequacies

E Not satisfactory, important task(s) poorly done or not attempted

F Very unsatisfactory, important task(s) poorly done or not attempted

Not applicable Not applicable. The Review Topic is not applicable or is irrelevant in the context of the statement

Source Lee and Colley (1992)

Table 2 Mitchell’s (1997) mitigation hierarchy guidelines form

Mitigation measure proposed in EIS Type of mitigation

Avoid Reduce Repair Compensate Enhance

1

2

3

The analysis of data was mainly descriptive, using Excel and STATA version 11. throughout this analysis, histograms and pie charts were plotted

Benchmarking the effectiveness of mitigation measures to the quality… 533

123

The regulations compel project proponents to submit EISs to the country’s EIA au-

thority, the Environmental Management Agency (EMA) for scrutiny before making the

final decision. Once the EIS is submitted, the authority’s technical review panel comprising

of a district, province, and national environmental officers determine the quality of EIS and

make recommendations. The duration of this process is 60 days after receiving the EIS.

Based on the outcome of the review, the authority can accept, reject, or recommend further

modifications to avoid future confrontation. If the EIS is accepted, an EIA license is issued

to the proponent.

There are seven major review areas of the EIS in the legislation, namely: (1) description

of the project and its activities to be undertaken; (2) reasons for selecting the project site;

(3) description of the likely impacts of the project on the environment; (4) measures to be

undertaken by project proponents to eliminate, reduce, or mitigate any anticipated adverse

impacts on the environment as well as identify ways of monitoring and managing the

environmental impacts of the project; (5) indicate whether the environment of any other

country is likely to be impacted by the project and measures to be taken to minimize such

impacts; (6) indicate how the proponent proposes to integrate biological diversity in the

project; and (7) describe the methodology used by the proponent to compile the EISs.

Based on the contents of EISs raised in the regulations, the preparation of EIS does not

specify or recommend any baseline studies. The regulations seem to assume that EIS

preparers will automatically describe the baseline environment during the description of

the project and its activities.

Part XI (99) (d) of the Environmental Management Act (chapter 20:27) define

‘‘mitigation’’ as ‘‘eliminating,’’ ‘‘reducing,’’ or ‘‘mitigating’’ any anticipated adverse ef-

fects of the project on the environment (Government of Zimbabwe, GOZ 2003). Sec-

tion 107 (1) further requires that:

Every developer shall take all reasonable measures to prevent or, if prevention is not

practicable, to mitigate any undesirable effect on the environment that may arise

from the implementation of his project (GOZ 2003: 391).

While avoidance and reduction are clearly specified as concrete types of mitigation,

there is no sequencing of these actions, nor are the actions of repairing, compensation and

enhancement provided.

4.2 Description of the baseline information

Seven key environmental categories were described under the baseline in the 22 EISs.

These included water, flora, fauna; soil, air, socioeconomic, and cultural environments.

The description of baseline environment was variable in quality, with 73 % of the EISs

graded C in terms of description of the environment (category 1.4). The description of the

environment was largely narratives based on observations and with no measurements of

raw data.

Although all EISs presented information on the description of the environment, estimates

of the baseline environmental condition (category 1.5) were generally unsatisfactory. Only

two EISs focusing on large-scale platinum-related mining and smelting specified the soil,

water, as well as estimated species richness and abundance in detail. Because of the small

sample size of EIS focusing on large-scale mines, it is not conclusive whether this result is

applicable to all EISs focusing on large-scale mines.

534 P. Gwimbi, G. Nhamo

123

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Benchmarking the effectiveness of mitigation measures to the quality… 535

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536 P. Gwimbi, G. Nhamo

123

The description of the baseline socioeconomic environmental conditions related to

issues such as existing economic and HIV and AIDS were rather weak. Only 9 % of the

EISs were rated satisfactory in this category.

4.3 Quality of EISs in terms of impact identification and evaluation

A total of 919 impacts were identified in the 22 reviewed EISs. The operations phase had

the highest number of impacts, accounting for 79 % of the identified impacts. The con-

struction phase with 137 (15 %) impacts had the second highest number. The decom-

missioning phase had the smallest number at 55 (6 %) impacts.

Table 3 summarizes the major environmental aspects and impacts described in the

reviewed EISs. The common impacts associated with gold and platinum group metals

(PGMs) mining and processing activities were related to acid mine drainage pollution of

surface and underground water and siltation of surface water bodies. The chemicals at-

tributed to pollution were mercury, cyanide, and sulfides from gold panning, rock waste

dumps, and tailing dams.

Air pollution issues emphasized in two EISs on PGMs mining and included fugitive

dust particles, carbon dioxide, and sulfur dioxide. Drilling, blasting and fugitive dust

attributed for more than 88 % of the air pollutants in all the 22 EISs. Emissions of these

pollutants were viewed as potentially harmful to both human health and the environment.

Ecological impacts were highlighted mainly in relation to the actual mining activities

and their physical disturbances. Increased demand for wood from workers as a fuel was

highlighted as a significant threat to forests in 13 of the 22 EISs. Invasive species invasions

were reported in six EISs.

Noise pollution was reported in 21 of the 22 EISs. Most of the noise was attributed to

the blasting, ground vibrations, and machinery movement. Of the 56 noise cases reported,

37 (66.1 %) were attributed to blasting and related ground vibrations. The remaining

34.9 % were attributed to noise from machinery. Noise pollution was also reported to

frighten animals as well as interfere with their breeding. Archeological and wildlife im-

pacts were the least represented impacts at 0.5 % of the total impacts.

Socioeconomic impacts were largely related to employment, conflicts resulting from

unfair compensation, crime, resentments to relocations, and infrastructural developments.

Positive socioeconomic benefits were over emphasized in 86 % of the EISs. Negative

impacts such as issues of land disputes, prostitution and crime, compensation disagree-

ments were highlighted in 23 % of the EISs.

The overall quality of EISs in terms of impact identification indicated that 68 % of the

EISs were of satisfactory (grades A–C) quality. The most common grade was B (generally

satisfactory), followed by C (just satisfactory).

More than 41 % of the EISs were rated unsatisfactory in category 2.4. This category

deals with the impact identification methodologies. Most of the EISs relied on arbitrary

qualitative methods in their impact prediction. As a follow-up with these EISs, prediction

of impacts was identified as deficient. Comparatively, two EISs focusing on large-scale

mines provided detailed methodologies.

The subcategory dealing with stakeholders’ consultation (sub-category 2.3.5) revealed

that 20 of the 22 EISs were graded as satisfactory. All the EISs contained enough infor-

mation on numerous public consultations between project proponents and residents of

affected communities as well as relevant statutory bodies. The number of stakeholders

consulted, however, varied with each EIS reviewed. In 19 EIS, the number of stakeholders

consulted ranged between 10 and 15. In three EISs including all the two focusing on large-

Benchmarking the effectiveness of mitigation measures to the quality… 537

123

scale mines, the number of stakeholders consulted exceeded 30 and included stakeholders

with indirect interests such as policy makers and water users downstream of the projects.

4.4 Quality of EISs in terms of alternatives and mitigation measures

The ratio of proposed mitigation measures to identified impacts was 908:919, respectively.

The proposed mitigation measures matched identified impacts. Most mitigation measures

presented were for direct impacts of projects. Like in the impact identification, the op-

erational phase received the highest number of mitigation measures at 567 (62.4 %). The

construction phase was second in terms of mitigation measures allocation at 208 (23 %).

The decommissioning phase had the lowest number of mitigation measures at 195

(21.3 %).

The principal mitigation measures mentioned in EISs were avoiding water pollution,

controlling erosion and sedimentation caused by mining activities, comprehensive man-

agement of all forms of waste, compensatory measures for destroyed forests, and pro-

tecting wildlife from human activities such as poaching (Fig. 4).

The distribution of other mitigation measures by environmental aspect included ecology

(12.3 %), socioeconomic benefits (10.7 %), land degradation (9.9 %), noise pollution

(8.5 %), air pollution (4.6 %), fire hazards (4.4 %), and health hazards (4.3 %).

About 77 % of the EISs were graded satisfactory in terms of the alternatives and

mitigation review area (Fig. 5). The most unsatisfactory was category 3.1, which deals

with alternatives. The ‘‘no-action scenario’’ was the most recommended in 68 % of the

EISs. Two EISs (9 %) focusing on large-scale mines suggested design alternatives to avoid

some impacts. In these two cases, technical alternatives were provided on hazardous waste

landfill developments, followed by alternative processes for treating acid mine drainage

(Table 4).

Fig. 5 Quality of EISs in terms proposed mitigation measures

Fig. 4 Quality of EISs in terms of impact identification and evaluation

538 P. Gwimbi, G. Nhamo

123

T a b le

4 M

it ig

a ti

o n

m e a su

re s

p ro

p o se

d in

E IS

s

E n

v ir

o n

m e n

ta l

is su

e im

p a c te

d N

a tu

re o

f im

p a c t

M it

ig a ti

o n

m e a su

re s

p ro

p o se

d N

u m

b e r

o f

E IS

s w

it h

m it

ig a ti

o n

P e rc

e n

ta g

e o

f to

ta l

E IS

s

W a te

r S

il ta

ti o n

R e st

ri c ti

n g

m o v e m

e n t

o f

m a c h in

e ry

to d e si

g n a te

d a re

a s,

m in

im iz

in g

v e g e ta

ti o n

c le

a ra

n c e ,

e a rt

h w

o rk

s m

a n

a g

e m

e n

t, c o

n to

u r

ri d

g e s,

re -v

e g

e ta

ti o

n 2

2 1

0 0

C o

n ta

m in

a ti

o n

C o n

st ru

c ti

n g

st a n

d a rd

ta il

in g

s d

a m

s/ p

o n

d s,

m o n

it o

ri n

g ,

tr a in

in g

w o

rk e rs

, w

a st

e st

a b

il iz

a ti

o n

, re

c y c li

n g

, tr

e a ti

n g

a c id

m in

e d

ra in

a g e ,

c o

n tr

o l

st o rm

w a te

r, fe

n c e

p o

n d s

a n

d ta

il in

g s

d a m

s 1

6 7

2

W a te

r d

e p

le ti

o n

R a in

w a te

r h

a rv

e st

in g

, re

st ri

c ti

n g

w a te

r u

se 7

3 2

F lo

o d in

g ri

sk s

P u

m p in

g o

u t

e x c e ss

w a te

r, w

a te

r d

iv e rs

io n

4 1

8

A ir

F u

g it

iv e

d u

st S

p ri

n k

le w

a te

r o

n su

rf a c e ,

d u

st su

p p re

ss io

n m

e a su

re s,

re st

ri c ti

n g

m o

v e m

e n

t, p

ro v

is io

n o

f sa

fe ty

c lo

th e s

to w

o rk

e rs

, re

g u la

r c h e c k u p

fo r

w o rk

e rs

, h e a lt

h e d u c a ti

o n , v e g e ta

te ro

c k

w a st

e d

u m

p s

2 2

1 0

0

E x

h a u st

g a se

s M

a in

ta in

m a c h in

e ry

, m

o n

it o

ri n

g 6

2 7

G a se

s fr

o m

m in

e ra

l sm

e lt

in g

M a in

ta in

m a c h in

e ry

, m

o n

it o

ri n

g ,

in v e st

in n

e w

te c h

n o

lo g

ie s,

c le

a n

g a se

s 3

1 4

P o

o r

v e n

ti la

ti o

n E

n su

re a d

e q

u a te

sh a ft

v e n

ti la

ti o

n ,

m o

n it

o ri

n g

2 9

E c o lo

g y

In v a si

v e

sp e c ie

s D

e st

ro y

a ll

a li

e n

in v a si

v e

sp e c ie

s, e n v ir

o n m

e n ta

l e d u c a ti

o n

3 1

4

D e fo

re st

a ti

o n

M in

im iz

e v e g e ta

ti o n

re m

o v a l,

re st

ri c t

c le

a ra

n c e

to d e si

re d

a re

a s

o n ly

, c o m

p e n sa

te d e st

ro y e d

fo re

st s,

e st

a b li

sh in

d ig

e n o u s

v e g e ta

ti o n

se e d

b a n k s,

c re

a te

g re

e n

b a n k s,

re h a b il

it a te

d is

tu rb

e d

a re

a s

w it

h si

m il

a r

v e g e ta

ti o n

a s

b e fo

re ,

e st

a b li

sh in

d ig

e n o u s

tr e e

n u rs

e ri

e s

1 7

7 7

B io

d iv

e rs

it y

d e p

le ti

o n

R e st

ri c t

e c o sy

st e m

d is

tu rb

a n c e ,

e n v ir

o n m

e n ta

l a w

a re

n e ss

, p re

se rv

e e n d a n g e re

d sp

e c ie

s 5

2 3

S o

il /l

a n

d d

e g

ra d

a ti

o n

O p

e n

p it

s R

e h

a b il

it a te

a ll

o p

e n

p it

s, b

a c k

fi ll

in g

, la

n d

re c la

m a ti

o n

, p

la n

t tr

e e s

a n

d g

ra ss

o n

re h

a b

il it

a te

d la

n d s,

st o

c k

m a te

ri a l

fo r

re c la

m a ti

o n

1 0

4 5

S o

il /l

a n

d c o n

ta m

in a ti

o n

M in

im iz

e o il

le a k a g e s,

c o n st

ru c t

st a n d a rd

p o n d s

a n d

ta il

in g s

d a m

s, m

o n it

o r

so il

q u a li

ty re

g u

la rl

y 6

2 7

S o

il e ro

si o n

C o n

st ru

c t

c o n

to u

r ri

d g

e s

w h

e re

sl o p

e is

st e e p

, in

st it

u te

e ro

si o n

c o

n tr

o l

m e a su

re s,

u se

w a st

e ro

c k

to m

a in

ta in

ro a d

s, re

h a b

il it

a te

g u

ll ie

s 1

2 5

5

Benchmarking the effectiveness of mitigation measures to the quality… 539

123

T a b le

4 c o

n ti

n u e d

E n

v ir

o n

m e n

ta l

is su

e im

p a c te

d N

a tu

re o

f im

p a c t

M it

ig a ti

o n

m e a su

re s

p ro

p o se

d N

u m

b e r

o f

E IS

s w

it h

m it

ig a ti

o n

P e rc

e n

ta g

e o

f to

ta l

E IS

s

L a n

d sc

a p

e E

x c a v

a ti

o n

s R

e c la

m a ti

o n

o f

d e g

ra d

e d

la n

d s

3 1

4

W a st

e H

a z a rd

o u s

c h e m

ic a ls

T ra

in in

g ,

a w

a re

n e ss

, p ro

v id

e w

a st

e b in

s to

e m

p lo

y e e s

8 3

6

F ir

e h

a z a rd

s F

ir e

h a z a rd

s P

re v

e n

t fi

re s

in fi

re -p

ro n e

a re

a s,

m a in

ta in

fi re

e q

u ip

m e n

t, tr

a in

w o

rk e rs

in fi

re fi

g h

ti n

g ,

c re

a te

fi re

g u

a rd

s 5

2 3

N o is

e G

ro u n d

v ib

ra ti

o n s

P ro

v id

e w

o rk

e rs

w it

h e a r

p lu

g s,

w a rn

in g

si re

n s

6 2

7

M a c h

in e ry

P ro

v id

e w

o rk

e rs

w it

h e a r

p lu

g s,

re st

ri c t

v e h

ic le

m o

v e m

e n

t 1

3 5

9

B la

st in

g P

ro v id

e w

o rk

e rs

w it

h e a r

p lu

g s,

w a rn

in g

si re

n s,

c o n fi

n e

b la

st in

g to

d a y

ti m

e ,

m o n it

o r

b la

st in

g 1 4

6 4

H e a lt

h H

IV /A

ID S

P ro

v id

e w

o rk

e rs

c o n d o m

s, h e a lt

h e d u c a ti

o n ,

e m

p lo

y lo

c a ls

1 6

7 2

H e a lt

h in

fr a st

ru c tu

re B

u il

d n e w

c li

n ic

s, a w

a re

n e ss

p ro

g ra

m m

e s

1 2

5 5

O c c u p

a ti

o n

a l

a n

d S

a fe

ty is

su e s

In ju

ry ,

a c c id

e n ts

E n su

re a d e q u a te

v e n ti

la ti

o n , e st

a b li

sh sa

fe ty

ru le

s, p ro

v id

e p ro

te c ti

v e

e q u ip

m e n t,

tr a in

w o rk

e rs

o n

sa fe

ty is

su e s,

se rv

ic e

m a c h in

e ry

, re

g u

la r

c h

e c k

u p

fo r

w o

rk e rs

, re

sc u

e te

a m

in p

la c e ,

a w

a re

n e ss

p ro

g ra

m m

e s,

e st

a b li

sh sa

fe ty

p ro

c e d u re

s, e st

a b li

sh sa

fe ty

b e n c h m

a rk

s

2 2

1 0

0

S o c io

e c o n o m

ic Jo

b s

fo r

lo c a ls

G iv

e fi

rs t

p re

fe re

n c e

to lo

c a ls

fo r

a ll

jo b s

2 2

1 0 0

C o

n fl

ic ts

o v

e r

c o m

p e n sa

ti o n

o f

la n

d

E n

su re

th a t

c o

m p

e n

sa ti

o n

fo r

lo st

la n

d a n

d o

th e r

re so

u rc

e s

is fa

ir ,

m a in

ta in

d ia

lo g

w it

h lo

c a l

c o

m m

u n

it ie

s, m

o n

it o

r c o

m m

u n

it ie

s’ w

a te

r q

u a li

ty 1

9 8

6

In c re

a se

d c ri

m e

In tr

o d u c e

p o li

c e

p a tr

o ls

, c ri

m e

a w

a re

n e ss

, sc

re e n

a ll

e m

p lo

y e e s

1 7

7 7

Im p

ro v

e d

q u

a li

ty o

f li

fe B

u il

d in

fr a st

ru c tu

re fo

r lo

c a l

c o

m m

u n

it ie

s, e m

p lo

y lo

c a ls

, c u

m u

la ti

v e

in v

e st

m e n

ts in

lo c a l

c o m

m u n it

ie s,

o ff

e r

b e tt

e r

sa la

ri e s,

p ro

v id

e a c c o m

m o d a ti

o n

2 1

9 5

W il

d li

fe P

o a c h in

g A

w a re

n e ss

, c ri

m in

a li

z e

p o a c h in

g ,

m in

im iz

e w

il d li

fe h a b it

a t

d e st

ru c ti

o n

4 1

8

C u

lt u

ra l

D e st

ru c ti

o n

o f

a rc

h e o

lo g

ic a l

si te

s

L o

o k

o u

t fo

r a n

y a re

a s

o f

c u

lt u

ra l

in te

re st

3 1

4

540 P. Gwimbi, G. Nhamo

123

The plan details of how proposed mitigation measures were to be implemented and

monitored were provided in 86 % of the EISs. The prescribed features that needed to be

monitored and frequency of monitoring were clearly articulated in these EISs. However, no

performance standards with which the effectiveness of implemented mitigation measures

was to be measured against were provided.

4.5 Mitigation measures proposed in EISs

The mitigation included in EISs by type is shown in Fig. 6. The greatest number of types of

mitigation measures focused on impact reduction (Fig. 6). Impact reduction actions were

more than twice the second highest type of mitigation measure proposed as shown in Fig. 6.

Table 5 shows the specific actions aimed at reducing the impacts that were proposed.

Dust suppression measures, improved ventilation, and establishment of safety rules, putting

in place rescue teams, and awareness measures were covered by all 22 EISs. The least

proposed reduction measures focused on constructing interceptors to collect used oils (one

EIS) as well as waste collection (five EISs).

Avoidance measures constituted 23.61 %) of the 908 mitigation measures indentified in

the EISs. The most avoided environmental impact related to water and ecology. Envi-

ronmental control measures comprising actions to avoid included avoiding unnecessary

vegetation clearance and use of hazardous chemicals. In relation to health impacts,

avoidance measures included use of personal protective equipment, HIV and AIDS

warning signs, and sex education awareness programs.

Alternatives aimed at avoiding some impacts included the engineering design of the solid

waste landfill through the layering of the surface with impermeable clay material in order to

prevent leachate leaching and thus prevent underground water pollution. It was proposed that

the generated leachate be collected for treatment before being released into the environment.

Fig. 6 Types of mitigation measures proposed in EISs

Benchmarking the effectiveness of mitigation measures to the quality… 541

123

Other preventive designs included technology at the tailings to prevent acid mine drainage

from polluting underground water, and the construction of underground hazardous waste

storage tanks where treated hazardous solid waste would be permanently stored.

Impact repairing was recommended in 77 % of the EISs. The forms of remediation

included the treatment of contaminated soils, treatment of sick workers, water recycling,

and treatment of contaminated water. Repairing, however, accounted for the least number

of mitigation measures, at only 7.4 % of the recommended mitigation measures.

Compensatory measures constituted 9.4 % of the proposed 908 mitigation measures and

focused on the rehabilitation of the degraded lands and restoring destroyed vegetation.

Restoration of the indigenous trees and grasses was recommended in 77 % of the EISs.

Measures such as creating indigenous green banks, replacing lost vegetation, seed har-

vesting, and planting were commonly proposed. Replacing the lost habitat which could not

be restored was proposed in 23 % of the EISs.

Impact enhancement actions were associated with the positive socioeconomic expec-

tations. The enhancing measures focused on employment of the locals, improved service

delivery, new infrastructure, and improvement of general standard of living.

Table 5 Measures proposed to minimize environmental impacts

Mitigation measure recommended Number of EISs recommending the mitigation measure

Dust suppression 22

Monitoring 22

Acid mine drainage management 11

Water treatment 16

Rain water harvesting 7

Flood risk management measures 4

Minimizing vegetation clearance 17

Soil erosion management 12

Management of chemicals and their storages 16

Putting in place oil interceptors 1

Waste segregation at source 5

Providing workers with ear plugs and restricting vehicle movement 13

Warning sirens before blasting 9

Confining blasting to certain time periods 9

Providing workers with condoms to minimize HIV/AIDS spread 16

Ensuring adequate ventilation for underground shafts 22

Establishing safety rules and providing workers with protective equipment

22

Regular checkup for workers 22

Putting in place rescue teams in case of accidents 22

Fair compensation for lost land and other resources to minimize conflicts 19

Introducing police patrols to minimize crime 17

Minimizing wildlife habitat destruction 4

Awareness measures to minimize impact of all environmental aspects 22

Putting in place warning signs 6

542 P. Gwimbi, G. Nhamo

123

5 Discussion

The main objective in undertaking this study was to gain a better understanding of the quality

of EIS and its likely influence on the effectiveness of its proposed mitigation measures. A

framework was introduced based on the literature to assess the quality of EIS as an indicator

of the likely effectiveness of proposed mitigation measures. The results showed that the

quality of 77 % of reviewed EISs was satisfactory in terms of proposed mitigation measures.

The influence of such EISs on decision making cannot be doubted. The result contributes to

the scientific knowledge on how mitigation performance is influenced by quality of EISs. The

results also provide some limited support for the proposition that the EISs can be used for

decision making or for the proposition that they can be used for decision justification.

Because of the legal requirement, project proponents are bound to consult such EISs espe-

cially if the regulations are enforced by the EIA authority.

Provision for monitoring the effectiveness of mitigation measures proposed in EISs was

included in 86 % of the 22 reviewed EISs. This provision reflects the general measures put

in place to assess the effectiveness of proposed mitigation measures. Since monitoring is

mandatory according to the regulations, there is some form of guarantee that the identified

impacts will be mitigated in accordance with the undertakings made in EISs. On that basis,

some of the proposed mitigation measures have potential to be effective in protecting the

environment from mining activities. It is, however, difficult to determine whether

mitigation measures proposed in EISs would be effective in compensating lost habitats

given its absence in the regulations and low coverage in EISs. There is a considerable risk

that significant adverse ecological impacts will not be compensated and much of the

natural habitat will be lost as proponents are not legally obliged. Some indications also

need to be given of the effectiveness of the proposed measures, based on some standards

criteria (Treweek and Thompson 1997).

The EIS review system is the responsibility of EMA, which bases its review on ex-

pertise of its environmental officers at district, province, and national center. On that basis,

the quality of reviewed EISs cannot be viewed in isolation of the EIA regulations. Analysis

of EIS quality showed high variation, especially between those focusing on large- and

small-scale mines, yet they were all approved as being enough to inform decision making.

Often, small-scale mine-focused EISs presented qualitative and poorly analyzed baseline

and impacts in a form that did not provide explanation of their significance to the

mitigation measures proposed. The copy–paste from previous EISs without any elaboration

of data reduced the quality of most EISs significantly. Based on such results, the review

process by the EIA authority technical team fell short of the quality review package

indicators for good-quality EISs. Most EISs focusing on small-scale mines had low-quality

grades to make informed decision. Against this background, previous studies argue that the

EIS review in most developing countries suffer from lack of qualified expertise working in

government for such activities (Mwakaje 2013). Yet the importance of such skills is well

documented in the literature (Morrison-Saunders and Bailey 2009). The need for au-

tonomous scientific professionals to be involved in reviewing EISs has been argued for in

the related literature as an alternative solution to such challenges (Morrison-Saunders and

Bailey 2009).

The tightening of approval conditions under the current EIA regulations in the country

also suggest that adherence to EIA regulations is critical and elevates procedures over

substantive measures. As a result, the way mitigation is conceptualized in the regulation

could explain some of the gaps identified in EISs regarding the proposed mitigation

Benchmarking the effectiveness of mitigation measures to the quality… 543

123

measures. Section 99(d) of the Environmental Management Act (Chapter 20:27) concep-

tualizes mitigation as ‘‘eliminating,’’ ‘‘reducing,’’ or ‘‘mitigating’’ adverse impacts. While

this is already confusing, the failure to provide compensatory measures could be one of the

reasons why proponents do not restore natural ecosystems destroyed by mining activities

along the Great Dyke. Given that, mining by its nature cannot avoid most ecological issues,

compensating degraded forests is essential as part of the conditions under which mining

activities should be allowed to go ahead. The view of this study is that compensation of the

ecological function of the ecosystem is weak in reviewed EISs and because regulations do

not enforce it, proponents are not bound to consider such recommendations in EISs.

Having well-defined mitigation criteria could provide an unambiguous measure of the

effectiveness of proposed measures.

6 Conclusion

This paper introduced a conceptual framework which aims to clarify the relationships

between quality of EIS and effectiveness of proposed mitigating measures. The study has

shown one way in which this framework can be operationalised. The quality of EIS is

useful in indicating the likely effectiveness of its proposed mitigation measures. However,

it is only a guide, as the proposed mitigation measures have to be implemented and

monitored. The results, however, provide indicative evidence of the likely effectiveness of

proposed mitigation measures based on the quality of EISs. While there is considerable

room for improvement, the quality of reviewed EISs has potential to contribute some

educated judgments during decision making. For this reason, reviewing the quality of EISs

is crucial in order to provide feedback mechanisms that effectively protect the environment

from project development activities such as mining.

The findings show a high degree of variation in the quality of EISs focusing on large-

scale mines and those on small-scale mines. The quality of EISs focusing on large-scale

mines was notably better compared with those on small scale. This may be a reflection of

funding allocated to EIAs by both large and small scale mines. Small-scale miners appear

to be inadequately funding EIA studies in order to avoid costs, and this is done partly

because of the perceived weaknesses in the regulatory and enforcement systems. EIS

review by the EIA authority itself was also not found to be consistent, given the approval

of EISs of such diverse quality. Building the capacity of reviewers, EIA consultants and

law enforcers to make the EIA process consistent is recommended. This could reduce the

disparities noted in the results. Monitoring and enforcement of approved EIS recom-

mended mitigation measures could also resolve this.

The analysis of EIA regulations in Zimbabwe revealed that the concept ‘‘mitigation’’ is

vaguely defined as the actions that constitute it do not show any prioritized sequence and

therefore do not compel consultants to abide by when proposing mitigation measures in

EISs. Additionally, the absence in the regulations of actions such as compensation for lost

environmental values was identified as one of the shortcomings. There is no explicit

provision in the EIA regulations for compensation if ecological functions are destroyed by

mining activities. If Mitchell’s (1997) mitigation hierarchy were to be followed in practice

for mining activities, compensation would most likely be the option, given that it is most

unlikely to avoid most ecological issues in mining.

It is also clear from the analysis of EISs that while it is an indicator of mitigation

effectiveness, the role is limited. A good-quality EIS on its own does little to guarantee the

544 P. Gwimbi, G. Nhamo

123

effectiveness of its proposed mitigation measures. There is a strong argument in the

literature that such mitigation commitments should be implemented and monitored, re-

ported, and audited.

Acknowledgments This work was supported by research grants from the University of South Africa (UNISA) Financial Aid Bureau and the Exxaro Chair in Business and Climate Change of UNISA. We also wish to extend our thanks to consenting proponents and EIA consultants who accessed their EISs for review. Opinions, findings, and conclusions or recommendations expressed in this paper are those of the author and do not necessarily reflect the views of the consenting and funding organizations. The authors declare that they have no conflict of interest.

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