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Environmental and Social YoungProfsNet Development Practitioners Project proposal: Review and evaluation of Environmental Impact Assessment reports on filling station projects in South Africa Project goal To review and evaluate critically the quality of Environmental Impact Assessment reports on filling station projects in South Africa. Objectives 1. To review recent Environmental Impact Assessment (EIA) reports that have been approved by the lead authority: Department of Environmental Affairs, for learning purposes. 2. To analyze the reports with reference to legal and regulatory compliance as well as best practice standards and existing guidelines, based on established criteria. 3. To determine if the EIA’s conducted on filling stations comply with legal and regulatory requirements, meet a number of generally accepted quality criteria and available best practice guidelines and standards. Background to Environmental Impact Assessment Environmental Impact Assessment (EIA) was first established as a response to increasing concerns regarding the environmental effects of major developments (IEMA, 2004). The United States (US) became the pioneer country to establish the first comprehensive environmental protection law, known as the National Environmental Policy Act (NEPA) in 1969. NEPA provided a baseline for EIA legislation throughout the world. Environmental impact assessment is a policy and management tool for both planning and decision-making (Glasson, Therivel & Chadwick, 2005; Modak & Biswas, 1999). EIA’s seek to assess the environmental and social and socio-economic impacts (both positive and negative) of proposed activities in order to promote sustainable development. EIA’s have been conducted since the 1970’s, however the first South African EIA regulations were promulgated in September 1997 as required in Sections 21, 22 and 26 of the Environment Conservation Act (Act 73 of 1989). The ECA EIA regulations were later later replaced by the National Environmental Management Act (NEMA) 107 of 1998 EIA. The newly promulgated NEMA EIA regulations recognize petrol stations as one of the activities for which a full EIA is mandatory (NEMA: EIA Regulations 2010 (GNR 543, 544, 545 and 546)). Regarding petrol stations, the current legislation states that only projects with tank capacities over 80 m3 are required to conduct an EIA. Lawrence (2003) defines EIA as a systematic process of: Determining and managing (identifying, describing, measuring, predicting, interpreting, integrating, communicating, involving and controlling) the potential (or real) impacts (positive and negative, direct and indirect, individual and cumulative, likelihood of occurrence) of proposed (or existing) human actions (projects, plans, programmes, legislation, activities) and

Transcript of South africaprojectprojectproposal20151102

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Environmental and Social

YoungProfsNet Development Practitioners

Project proposal: Review and evaluation of

Environmental Impact Assessment reports on filling station projects in South Africa

Project goal To review and evaluate critically the quality of Environmental Impact Assessment reports on filling station projects in South Africa.

Objectives 1. To review recent Environmental Impact Assessment (EIA) reports that have been approved

by the lead authority: Department of Environmental Affairs, for learning purposes. 2. To analyze the reports with reference to legal and regulatory compliance as well as best

practice standards and existing guidelines, based on established criteria. 3. To determine if the EIA’s conducted on filling stations comply with legal and regulatory

requirements, meet a number of generally accepted quality criteria and available best practice guidelines and standards.

Background to Environmental Impact Assessment Environmental Impact Assessment (EIA) was first established as a response to increasing concerns regarding the environmental effects of major developments (IEMA, 2004). The United States (US) became the pioneer country to establish the first comprehensive environmental protection law, known as the National Environmental Policy Act (NEPA) in 1969. NEPA provided a baseline for EIA legislation throughout the world. Environmental impact assessment is a policy and management tool for both planning and decision-making (Glasson, Therivel & Chadwick, 2005; Modak & Biswas, 1999). EIA’s seek to assess the environmental and social and socio-economic impacts (both positive and negative) of proposed activities in order to promote sustainable development. EIA’s have been conducted since the 1970’s, however the first South African EIA regulations were promulgated in September 1997 as required in Sections 21, 22 and 26 of the Environment Conservation Act (Act 73 of 1989). The ECA EIA regulations were later later replaced by the National Environmental Management Act (NEMA) 107 of 1998 EIA. The newly promulgated NEMA EIA regulations recognize petrol stations as one of the activities for which a full EIA is mandatory (NEMA: EIA Regulations 2010 (GNR 543, 544, 545 and 546)). Regarding petrol stations, the current legislation states that only projects with tank capacities over 80 m3 are required to conduct an EIA. Lawrence (2003) defines EIA as a systematic process of: Determining and managing (identifying, describing, measuring, predicting, interpreting, integrating, communicating, involving and controlling) the potential (or real) impacts (positive and negative, direct and indirect, individual and cumulative, likelihood of occurrence) of proposed (or existing) human actions (projects, plans, programmes, legislation, activities) and

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their alternatives on the environment (physical, chemical, biological, ecological, human health, cultural, social, economic, built, and interrelations). This definition shows that EIA is a process that blends many activities. The systematic exploration of interrelationships between the proposal and the environment and among alternatives and impacts is clearly crucial in EIA (Lawrence, 2003). In essence EIA is a systematic process that examines the environmental, social and socio-economic consequences of development actions and ensures that these effects are taken into account during project design (Glasson et al, 2005).

Effectiveness of Environmental Impact Assessment EIA can be an effective environmental management tool if it achieves three purposes: 1. assist the developer of a project 2. inform decision-making and 3. promote sustainable development (Glasson et al, 2005). As argued by Glasson et al (2005) EIA should be a means to good environmental (, social and socio-economic) management over the life of a project. Generally, it is agreed that EIA has led to improvements in the environmental (, social and socio-economic) management of development activities (Bailey, 1997; Glasson et al, 2005). However, the development of EIA practice has also been accompanied by a significant amount of literature that identifies numerous weaknesses: lack of consideration of cumulative impacts, insufficient public participation, little monitoring and auditing, limited influence on the decision making process, inadequate consideration of alternatives and the poor quality of environmental impact assessment reports have been highlighted as weaknesses of current practice (Glasson et al, 2005; Mokhehle & Diab, 2001; Wood, 2003).

Project approach To achieve the objectives of the project a team of members of YoungProfsNet will carry out the review and collectively produce a report. Each EIA report will be reviewed independently by three members of the project team and the EIA reports will be assigned for review to members in such a way that each report will be reviewed by a different trio of team members. The team shall set SMART (Specific, Measurable, Achievable, Realistic and Time-based) targets for the execution of the project. These targets will set a timeline for the project work to meet the project objectives. The resulting report will be peer-reviewed by other YoungProfsNet members. The project report may be the basis for a formal publication.

Review and evaluation

Review checklists A simple and effective review technique is to use a checklist with pre-defined questions. Checklists are useful to review the completeness of an EIA. There are several review checklists available internationally that can be used and adapted to meet the requirements of the project. An example is the review checklist used by the Southern African Institute for Environmental Assessment (SAIEA) that is subdivided into the following eight sections: 1. Methodology used in compiling the EIA report 2. Description of the project 3. Assessment of alternatives to the project

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4. Description of the environment 5. Description of impacts (a description of the affected environment (baseline conditions) and

an estimation and prediction of the main impacts) 6. Consideration of measures to mitigate impacts (necessary measures or environmental

management plan identified, including follow up and monitoring arrangements and a specification of contingency plans and non-standard operating responses)

7. Non-technical summary

Evaluation criteria Each report will be reviewed separately and evaluated according to a number of criteria: 1. Readability 2. Clarity 3. Comprehensiveness 4. Appropriate use of maps, tables, figures, graphs and other illustrations 5. Readability and clarity of the non-technical summary for the general public 6. Public availability of other information/communication material for specific (groups of)

stakeholders 7. Compliance with the National Environmental Management Act (107/1998): Environmental

Impact Assessment Regulations, 2014 Reports meeting these seven criteria (and the SAIEA criteria) satisfactorily are judged to conform to good impact assessment practice. EIA reports meeting the additional review criteria, the IFC Performance Standards and conforming to ISO14000 would be judged to represent good international impact assessment practice.

NEMA Environmental Impact Assessment Regulations 2014

1.1 Details of the EAP who prepared the report

1.2 Details of the expertise of the EAP, including a curriculum vitae

2 The location of the activity, including

2.1 the 21 digit Surveyor General code of each cadastral land parcel

2.2 where available, the physical address and farm name

2.3 here the required information in items 2.1 and 2.2 is not available, the coordinates of the boundary of the property or properties

3 A plan which locates the proposed activity or activities applied for as well as the associated structures and infrastructure at an appropriate scale, or, if it is

3.1 a linear activity, a description and coordinates of the corridor in which the proposed activity or activities is to be undertaken

3.2 on land where the property has not been defined, the coordinates within which the activity is to be undertaken

4 A description of the scope of the proposed activity, including

4.1 all listed and specified activities triggered and being applied for

4.2 a description of the associated structures and infrastructure related to the development

5 A description of the policy and legislative context within which the development is located and an explanation of how the proposed development complies with and responds to the legislation and policy context

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6 A motivation for the need and desirability for the proposed development, including the need and desirability of the activity in the context of the preferred location

7 A motivation for the preferred development footprint within the approved site

8 A full description of the process followed to reach the proposed development footprint within the approved site, including

8.1 details of the development footprint alternatives considered

8.2 details of the public participation process undertaken in terms of regulation 41 of the Regulations, including copies of the supporting documents and inputs

8.3 a summary of the issues raised by interested and affected parties, and an indication of the manner in which the issues were incorporated, or the reasons for not including them

8.4 the environmental attributes associated with the development footprint alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects

8.5 the environmental attributes associated with the development footprint alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects

8.5.1 can be reversed

8.5.2 may cause irreplaceable loss of resources

8.5.3 can be avoided, managed or mitigated

8.6 the methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks

8.7 positive and negative impacts that the proposed activity and alternatives will have on the environment and on the community that may be affected focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects

8.8 the possible mitigation measures that could be applied and level of residual risk

8.9 if no alternative development locations for the activity were investigated, the motivation for not considering such

8.10 a concluding statement indicating the preferred alternative development location within the approved site

9 A full description of the process undertaken to identify, assess and rank the impacts the activity and associated structures and infrastructure will impose on the preferred location through the life of the activity, including

9.1 a description of all environmental issues and risks that were identified during the environmental impact assessment process

9.2 an assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures

10 an assessment of each identified potentially significant impact and risk, including

10.1 cumulative impacts

10.2 the nature, significance and consequences of the impact and risk;

10.3 the extent and duration of the impact and risk

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10.4 the probability of the impact and risk occurring

10.5 the degree to which the impact and risk can be reversed

10.6 the degree to which the impact and risk may cause irreplaceable loss of resources

10.7 the degree to which the impact and risk can be mitigated

11 Where applicable, a summary of the findings and recommendations of any specialist report complying with Appendix 6 to these Regulations and an indication as to how these findings and recommendations have been included in the final assessment report

12 An environmental impact statement which contains

12.1 a summary of the key findings of the environmental impact assessment

12.2 a map at an appropriate scale which superimposes the proposed activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers

12.3 a summary of the positive and negative impacts and risks of the proposed activity and identified alternatives

13 Based on the assessment, and where applicable, recommendations from specialist reports, the recording of proposed impact management objectives, and the impact management outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions of authorisation

14 The final proposed alternatives which respond to the impact management measures, avoidance, and mitigation measures identified through the assessment

15 Any aspects which were conditional to the findings of the assessment either by the EAP or specialist which are to be included as conditions of authorisation

16 A description of any assumptions, uncertainties and gaps in knowledge which relate to the assessment and mitigation measures proposed

17 A reasoned opinion as to whether the proposed activity should or should not be authorised, and if the opinion is that it should be authorised, any conditions that should be made in respect of that authorisation

18 Where the proposed activity does not include operational aspects, the period for which the environmental authorisation is required and the date on which the activity will be concluded and the post construction monitoring requirements finalised

19 An undertaking under oath or affirmation by the EAP in relation to

19.1 the correctness of the information provided in the reports

19.2 the inclusion of comments and inputs from stakeholders and interested and affected parties

19.3 the inclusion of inputs and recommendations from the specialist reports where relevant

19.4 any information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested or affected parties

20 Where applicable, details of any financial provisions for the rehabilitation, closure, and ongoing post decommissioning management of negative environmental impacts

21 An indication of any deviation from the approved scoping report, including the plan of study, including

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21.1 any deviation from the methodology used in determining the significance of potential environmental impacts and risks

21.2 a motivation for the deviation

22 Any specific information that may be required by the competent authority

23 Any other matters required in terms of section 24(4)(a) and (b) of the Act

Additional review criteria Each report will also be assessed by the following additional criteria: 1. Are project construction and operation assessed separately (and are separate

environmental management plans for construction and operation presented) 2. Are normal and abnormal (maintenance, emergency situations) operations assessed 3. Are emergency control and recovery covered 4. Are cumulative and possible future impacts of project extension covered 5. Are abandonment and restoration addressed 6. Is the ‘post development’ (‘boom-bust’) situation following construction and at

abandonment assessed ? IFC Performance Standards While this may not be so relevant for filling station projects, external finance for project development (by development banks or commercial lenders) may require compliance with the IFC Performance Standards on Environmental and Social Sustainability (http://www.ifc.org/wps/wcm/connect/115482804a0255db96fbffd1a5d13d27/PS_English_2012_Full-Document.pdf?MOD=AJPERES

ISO14000 (Environmental Management Standard) conformity There would be considerable merit if impact assessment reports would be compatible with ISO14000 (by including a regulatory, an aspects and an impacts register) and the environmental, social and health management plans for construction and operation would meet ISO14000 requirements.

Review and evaluation summary The quality review of the EIA report involves evaluating how well the assessment tasks have been performed (Lee & George, 2000). The elements of EIA review and the aspects considered will differ with the requirements that are in place in a particular country. Reviews must establish a set of quality criteria to be met as well as a minimum standard for achieving these (Pretorius, 2006). A review of the EIA report should not just be a matter of checking that required information is presented. It should also consider the quality and success of the entire EIA process (Jalava et al, 2010). When evaluating EIA report quality, meeting legal and regulatory requirements is paramount.

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Review and evaluation rating An integrated checklist is given in Appendix 1. Checklist items will be rated as follows:

Rating Description 3 Satisfactory or good 2 Needs to be improved 1 Unsatisfactory 0 Not applicable; not available for review; not relevant

References and further reading GDACEL. (2001). EIA Administrative Guideline: Guideline for the Construction and Upgrade of Filling Stations and Associated Tank Installations. Johannesburg. Glasson, J., Therivel, R. & Chadwick, A. (2005). Introduction to Environmental Impact

Assessment. 3rd Edition. London: Routledge. pp. 222-223. Government Notices R. 982 (2014). National Environmental Management Act

(107/1998): Environmental Impact Assessment Regulations. Government Gazette Vol. 594 (No. 38282): 3-74.

IEMA (2004). Guidelines for Environmental Impact Assessment, Lincoln: IEMA. IEMA (2011). The State of Environmental Impact Assessment Practice in the UK (Special

Report), Lincoln: IEMA Jalava K., Pasanen S., Saalasti M. & Kuitunen M. (2010). Quality of Environmental Impact

Assessment: Finnish EISs and the opinions of EIA professionals. Impact Assessment and Project Appraisal 28(1):15-27.

Kruger, R. (2012). A critical analysis of the quality of EIA reports for filling stations in South Africa. MSc thesis, North-West University, Potchefstroom.

Lawrence, D.P. (2003). Environmental Impact Assessment: Practical Solutions to Recurrent Problems. John Wiley & Sons: New Jersey.

Lee, N. & George, C. (2000). Environmental Assessment in Developing and Transitional Countries. John Wiley & Sons Ltd: Chichester.

Lee, N., Colley, R., Bonde, J. & Simpson, J. (1999). Reviewing the quality of environmental statements and environmental appraisals. Occasional Paper number 55, EIA Centre, Department of Planning and Landscape, University of Manchester, Manchester.

Modak, P. & Biswas, A.K. (1999). Conducting Environmental Impact Assessment in Developing Countries. Tokyo: UN University Press.

Mokhehle, L. & Diab, R. (2001). Evolution of environmental impact assessment in a small developing country: A review of Lesotho case studies from 1980 to 1999. Impact Assessment and Project Appraisal 19(1):9-18.

Pretorius, H.M. (2006). The quality of environmental impact reports in the North-West province, South Africa. MSc thesis, North-West University, Potchefstroom.

Warburton, C.L. (2014). Evaluating South African Environmental Impact Assessment (EIA) processes in the context of the Gautrain Project. LLM thesis, University of the Witwatersrand., Johannesburg.

Wood, C. (2003). Environmental Impact Assessment in Developing Countries: An Overview. Retrieved from http://www.environment-integration.org/Download /D123/Wood.pdf

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2 November 2015 Contact: Miss Thembie Ndlovu (YoungProfsNet project lead) email: [email protected] Maarten Smies (YoungProfsNet project mentor) email: [email protected]

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Appendix 1. Integrated checklist of criteria for the review and evaluation of Environmental Impact Assessment reports on filling station projects in South Africa

General criteria

1 Readability

2 Clarity

3 Comprehensiveness

4 Appropriate use of maps, tables, figures, graphs and other illustrations

5 Readability and clarity of the non-technical summary for the general public

6 Public availability of other information/communication material for specific (groups of) stakeholders

Criteria Southern African Institute for Environmental Assessment (SAIEA)

1 Methodology used in compiling the EIA report

2 Description of the project

3 Assessment of alternatives to the project

4 Description of the environment

5 Description of impacts (a description of the affected environment (baseline conditions) and an estimation and prediction of the main impacts)

6 Consideration of measures to mitigate impacts (necessary measures or environmental management plan identified, including follow up and monitoring arrangements and a specification of contingency plans and non-standard operating responses)

7 Non-technical summary

NEMA EIA Regulations (2014)

1.1 Details of the EAP who prepared the report

1.2 Details of the expertise of the EAP, including a curriculum vitae

2 The location of the activity, including

2.1 the 21 digit Surveyor General code of each cadastral land parcel

2.2 where available, the physical address and farm name

2.3 here the required information in items 2.1 and 2.2 is not available, the coordinates of the boundary of the property or properties

3 A plan which locates the proposed activity or activities applied for as well as the associated structures and infrastructure at an appropriate scale, or, if it is

3.1 a linear activity, a description and coordinates of the corridor in which the proposed activity or activities is to be undertaken

3.2 on land where the property has not been defined, the coordinates within which the activity is to be undertaken

4 A description of the scope of the proposed activity, including

4.1 all listed and specified activities triggered and being applied for

4.2 a description of the associated structures and infrastructure related to the development

5 A description of the policy and legislative context within which the development is located and an explanation of how the proposed development complies with and responds to the legislation and policy context

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6 A motivation for the need and desirability for the proposed development, including the need and desirability of the activity in the context of the preferred location

7 A motivation for the preferred development footprint within the approved site

8 A full description of the process followed to reach the proposed development footprint within the approved site, including

8.1 details of the development footprint alternatives considered

8.2 details of the public participation process undertaken in terms of regulation 41 of the Regulations, including copies of the supporting documents and inputs

8.3 a summary of the issues raised by interested and affected parties, and an indication of the manner in which the issues were incorporated, or the reasons for not including them

8.4 the environmental attributes associated with the development footprint alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects

8.5 the environmental attributes associated with the development footprint alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects

8.5.1 can be reversed

8.5.2 may cause irreplaceable loss of resources

8.5.3 can be avoided, managed or mitigated

8.6 the methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks

8.7 positive and negative impacts that the proposed activity and alternatives will have on the environment and on the community that may be affected focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects

8.8 the possible mitigation measures that could be applied and level of residual risk

8.9 if no alternative development locations for the activity were investigated, the motivation for not considering such

8.10 a concluding statement indicating the preferred alternative development location within the approved site

9 A full description of the process undertaken to identify, assess and rank the impacts the activity and associated structures and infrastructure will impose on the preferred location through the life of the activity, including

9.1 a description of all environmental issues and risks that were identified during the environmental impact assessment process

9.2 an assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures

10 an assessment of each identified potentially significant impact and risk, including

10.1 cumulative impacts

10.2 the nature, significance and consequences of the impact and risk;

10.3 the extent and duration of the impact and risk

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10.4 the probability of the impact and risk occurring

10.5 the degree to which the impact and risk can be reversed

10.6 the degree to which the impact and risk may cause irreplaceable loss of resources

10.7 the degree to which the impact and risk can be mitigated

11 Where applicable, a summary of the findings and recommendations of any specialist report complying with Appendix 6 to these Regulations and an indication as to how these findings and recommendations have been included in the final assessment report

12 An environmental impact statement which contains

12.1 a summary of the key findings of the environmental impact assessment

12.2 a map at an appropriate scale which superimposes the proposed activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers

12.3 a summary of the positive and negative impacts and risks of the proposed activity and identified alternatives

13 Based on the assessment, and where applicable, recommendations from specialist reports, the recording of proposed impact management objectives, and the impact management outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions of authorisation

14 The final proposed alternatives which respond to the impact management measures, avoidance, and mitigation measures identified through the assessment

15 Any aspects which were conditional to the findings of the assessment either by the EAP or specialist which are to be included as conditions of authorisation

16 A description of any assumptions, uncertainties and gaps in knowledge which relate to the assessment and mitigation measures proposed

17 A reasoned opinion as to whether the proposed activity should or should not be authorised, and if the opinion is that it should be authorised, any conditions that should be made in respect of that authorisation

18 Where the proposed activity does not include operational aspects, the period for which the environmental authorisation is required and the date on which the activity will be concluded and the post construction monitoring requirements finalised

19 An undertaking under oath or affirmation by the EAP in relation to

19.1 the correctness of the information provided in the reports

19.2 the inclusion of comments and inputs from stakeholders and interested and affected parties

19.3 the inclusion of inputs and recommendations from the specialist reports where relevant

19.4 any information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested or affected parties

20 Where applicable, details of any financial provisions for the rehabilitation, closure, and ongoing post decommissioning management of negative environmental impacts

21 An indication of any deviation from the approved scoping report, including the plan of study, including

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21.1 any deviation from the methodology used in determining the significance of potential environmental impacts and risks

21.2 a motivation for the deviation

22 Any specific information that may be required by the competent authority

23 Any other matters required in terms of section 24(4)(a) and (b) of the Act

GDACEL Gauteng guidelines for petrol stations

1 A 1:50 000 map and street map

2 Detailed site development plans; and must indicate the following: location of the site in relation and the distance of the tank(s) from council boundaries; lay-out of adjacent properties; current land use and zoning of the area; major roads, railways, open spaces; environmentally sensitive/significant features; places of social and cultural importance; seep lines, channels, dams, rivers and other water bodies; existing filling station within a 5 or 25 km radius (that which is applicable)

3 Description of the geology of the site with a description of the soil types in terms of compatibility

4 Detailed motivation on the need and desirability of the proposed development

5 Depth of the water table should be provided with a baseline reference of groundwater quality of the site and surrounding areas

6 The location of wells and boreholes on the site and neighbouring properties with an indication of the level of reliance of the neighbouring properties on ground water resources

7 A description of other environmental issues (eg socio-economic aspects related to the sense of place, visual impact, etc.) as a result of the construction, upgrade or the operation of the filling station

8 A description of the public participation process prescribed by the EIA regulation

9 Method of waste disposal from the premises. Details (quantity, quality and method)

10 Specific site design and recommendations for installation of underground tanks in relation to the receiving environment

11 If the proposed filling station will include a car wash, the following must be taken into account: manual vs. automated systems; water recycling practices; quantity and quality of the effluent discharged into the sewer must be determined in consultation with the relevant local authority

12 A comparative assessment (benefits vs. disadvantages) of alternatives, specifically location, land-use and the no-go option

13 In the case where there are existing filling stations in proximity, an assessment of the cumulative impacts on the environment, as a result of combined impacts from all filling stations in the applicable radius (5 or 25 km), must be undertaken:

13.1 the ability of the natural and social environment to assimilate cumulative stresses placed on them

13.2 the likelihood of negative synergistic effects

13.3 whether the proposed development has a significant impact on, or is constrained by existing or future development rights

13.4 the feed flow and anticipated traffic volume

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13.5 a feasibility study which includes the information in item 4, but not entirely based upon it

13.6 the demand (necessity) and desirability of the proposed development; with an indication of the potential of the proposed filling station in terms of fulfilling the need of the targeted consumer

13.7 impact on the feasibility of existing filling stations; the no-go option as an alternative

Additional review criteria

1 Are project construction and operation assessed separately

1.1 are separate environmental management plans for construction and operation presented

2 Are normal and abnormal (maintenance, emergency situations) operations assessed

3 Are emergency control and recovery covered

4 Are cumulative and possible future impacts of project extension covered

5 Are abandonment and restoration addressed

6 Is the 'post development' ('boom-bust') situation following construction and at abandonment assessed

ISO14000 conformity

Does the report contain a Regulatory register

Does the report contain an Aspects register

Does the report contain an Impacts register

Is the environmental management plan ISO14000 compatible

IFC Performance Standards on Environmental and Social Sustainability

1 Assessment and Management of Environmental and Social Risks and Impacts

1.1 Environmental and Social Assessment and Management System

1.2 Policy: environmental and social objectives and principles

1.3 Identification of environmental and social risks and impacts

1.4 Management Programme

1.5 Organizational Capacity and Competency

1.6 Emergency Preparedness and Response

1.7 Monitoring and Review

1.8 Stakeholder Engagement

1.9 External Communications and Grievance Mechanisms

1.10 Ongoing Reporting to Affected Communities

2 Labour and Working Conditions

2.1 Working Conditions and Management of Worker Relationship

2.2 Protecting the Work Force (child labour; forced labour)

2.3 Occupational Health and Safety

2.4 Workers Engaged by Third Parties

2.5 Supply Chain

3 Resource Efficiency and Pollution Prevention

3.1 Resource Efficiency (greenhouse gases; water consumption)

3.2 Pollution Prevention (wastes; hazardous materials management; pesticides use and management)

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4 Community Health, Safety, and Security

4.1 Community Health and Safety

4.2 Security Personnel

5 Land Acquisition and Involuntary Resettlement

5.1 General: project design; compensation and benefits for displaced persons; community engagement; grievance mechanism; resettlement and livelihood restoration planning and implementation

5.2 Displacement: physical displacement; economic displacement

5.3 Private Sector Responsibilities Under Government-Managed Resettlement

6 Biodiversity Conservation and Sustainable Management of Living Natural Resources

6.1 General: impact assessment; avoidance of impacts on biodiversity and ecosystem services

6.2 Protection and Conservation of Biodiversity (modified habitat; natural habitat; critical habitat; legally protected and internationally recognized areas; invasive alien species)

6.3 Sustainable Management of Living Natural Resources

6.4 Supply Chain

7 Indigenous Peoples

7.1 General: avoidance of adverse impacts; participation and consent

7.2 Circumstances Requiring Free, Prior, and Informed Consent (impacts on lands and natural resources subject to traditional ownership or under customary use; relocation from those; critical cultural heritage)

7.3 Mitigation and Development Benefits

7.4 Private Sector Responsibilities Where Government is Responsible for Managing Indigenous Peoples Issues

8 Cultural Heritage

8.1 Protection of Cultural Heritage in Project Design and Execution (chance find procedures; consultation; community access; removal of (non-) replicable cultural heritage; critical cultural heritage)

8.2 Project’s Use of Cultural Heritage