Thyspunt Environmental Report “fatally flawed” Continued
Flawed Thyspunt Impact Rating Criteria (IRCs)
These are the process by which the significance of an impact can be determined. They are crucial to decision-making. They were drafted by environmental consultants Gibb, who were appointed and have been paid by Eskom. They have been a point of contention for the past eight years.
The first set of criteria was criticised strongly by the Thyspunt Alliance on the grounds that the requirements were such that it was impossible to identify a fatal flaw. The peer group monitor found them incomprehensible, leading to the conclusion that none of the sites were suitable. A revised set was published in the 2011 Revised Draft, which contained some improvements, but, in the view of the Alliance was still unacceptable. The key issue was “Intensity”. Unless a high rating was awarded for intensity, it remained impossible to have a fatal flaw. The problem with this was that to justify a high rating, both the biophysical (natural) environment had to be destroyed and social, cultural and other factors had to be substantially affected. The complaint was that it was quite possible that one of these was true, whereas the other might be less so; and that in any case, no specialist, being a specialist, was competent to express a view on both groups.
A response to this was only received in September, 2015 (four years later!), in which the Environmental Impact Assessor (EAP) , the person running the EIA on behalf of consultants Gibb, conceded that it was not necessary for both sets of criteria to have a high rating, and that intensity could be rated high if either set was high.
This was a fundamental change, but the problem was that none of the specialists’ reports had been done on that basis. They all needed to be reviewed to determine whether the final significance rating would have been different in terms of the EAP’s interpretation. To have such a major correction at this stage in the EIA process is not acceptable.
The Alliance regards this deficiency in the Impact Rating Criteria as a fatal flaw. It could affect all 250 odd identified impacts.
Article by Hilton Thorpe, on behalf of the St Francis Kromme Trust, the St Francis Bay Residents’ Association and the Thyspunt Alliance