Guidelines for Environmental Impact Assessments (EIAs)
Environmental impact assessments (EIAs) are required in South Africa in terms of the National Environmental Management Act (Act 107 of 1998) (NEMA) and its associated EIA Regulations. Broadly speaking, developments likely to have a major impact require scoping and EIA, and those likely to have a lesser impact require a Basic Assessment. In both cases, many of the activities involve change of land use and thus often loss of natural habitat, which is the greatest threat to plant species in South Africa (see section 3.2). In terms of the principles of NEMA (Section 2), sustainable development requires the consideration of all relevant factors including disturbance of ecosystems and loss of biodiversity, both of which should be avoided or, if that is not possible, should be minimized and remedied.
If natural vegetation will be affected by a proposed development, a specialist botanical survey should be commissioned as part of the environmental assessment process. If a subpopulation of a species of conservation concern is found to occur on the proposed development site, it would be one indicator that the proposed activity is likely to result in loss of biodiversity, bearing in mind that loss of subpopulations of these species will either increase their extinction risk or may in fact result in their extinction. The detection of a threatened species on a site during an environmental assessment should result in a record of decision from the competent authority that avoids, mitigates, remedies or offsets loss of habitat for the species in question. The competent authority may also refuse authorisation for the proposed activity. In practice, the mitigation requirements that allow the proposed development to proceed, including the amount of natural habitat set aside, differ widely, depending on the environmental assessment practitioner's recommendations and the policies of the competent authority. In order to strengthen the environmental assessment process and improve consistency, this section provides:
- Guidelines for environmental assessment practitioners on how botanical specialists should be chosen and when and in what way botanical surveys should be conducted.
- Guidelines for botanical specialists on the specific recommendations that should be made if a species of conservation concern is found on a site as well as general recommendations for the habitat conservation of such species.
Species of conservation concern are only one aspect of biodiversity that should be considered in the EIA process. The presence of threatened ecosystems on the site and the role of the site in contributing to ecological processes are as important and are frequently neglected. Ecosystem guidelines for environmental assessment have been developed for the Western Cape Province (De Villiers et al. 2005) to assist environmental assessment practitioners and specialists to take the full range of the potential ecological impact into account, and can be developed for other provinces in future. Ecosystem guidelines for environmental assessment complement the guidelines given below.
General guidelines for environmental assessment practitioners and botanical specialists
South Africa's flora is highly diverse and is characterized by many regions where there are high levels of plant endemism. In addition, very different ecological processes that maintain species diversity are at work in the nine different biomes. For example, grassland systems require frequent burning (typically on a less than three-year rotation for maintenance of species), while the Thicket Biome does not burn. Vegetation types within biomes have different ecological needs, for example Cederberg Sandstone Fynbos is an arid fynbos system requiring fire at a longer time interval (typically 20 to 30 years) compared to the more mesic Fynbos on the Cape Peninsula where a fire return interval of between seven and 15 years is appropriate. Given the high levels of endemism and the need for local-scale ecological understanding, it is critical that only specialist botanists who are familiar with the ecology of the region in which the site occurs, are employed.
South Africa's highly diverse flora is characterized by many plant groups of which the species within a genus look vegetatively very similar and can only be told apart if flowering or fruiting. Most species of conservation concern are from such groups. There are also a number of species that are ephemeral and may appear only after a certain environmental event such as fire. Given this temporal element to species identification, it is vital that specialist surveys are conducted in the appropriate season, preferably during the flowering time of the species expected to occur in the local area. Within the summer-rainfall areas of the country this season is from October to April while in the winter-rainfall areas it is from August to October.
As part of the botanical survey, prior to visiting the site, the specialist consultant should download a list of species that could potentially occur at the site from POSA. This list is provided at the quarter degree square level of accuracy. At this broad scale, the list will often include many species that may not be found at the proposed site. However, any species of conservation concern indicated in the list as potentially occurring at the site should be well researched before a site visit is conducted to ensure that the specialist knows what to look for. In Gauteng, the provincial conservation authority also provides consultants with a list of species of conservation concern that may occur, or have actually been confirmed, on a site.
During a site visit, conducted in the most appropriate field season, it is very important that specimens are collected as part of the botanical survey, especially for taxonomic groups likely to be of conservation concern. Once specimens are collected, they should be identified at a herbarium. Potential species of conservation concern sampled should be identified by a taxonomist specializing in the plant group in question. Final species lists for sites produced by specialist consultants that include many species identified only to genus level, for example Gladiolus sp., Melolobium sp., should not be accepted by the Environmental Assessment Practitioner as of adequate quality, as it indicates that specimens were possibly not collected or were not identified at a herbarium. There will almost always be some species found on a site that cannot be identified because they are without flowers or fruit, and such species may be listed only as a genus without a specific epithet. It is therefore the overall proportion of unidentified species that should be an indication of how well a survey has been conducted. Specialist botanists should also include in their reports a list of species of conservation concern that may occur at a site but may be dormant as a result of unfavourable environmental conditions, for example species that were not seen because the vegetation at a site has not been burnt for many years.
Once a plant species list for a site has been obtained, their latest Red List status should be verified on this website. SANBI's Biodiversity Information Management unit is currently working on providing online tools whereby species lists from surveys can be uploaded and the correct taxonomy and latest Red List status will be generated automatically. Links will be provided here as soon as this system becomes available. If a species of conservation concern with a threat status marked a in the table below is found during a site survey, details on the subpopulation in question should be provided to SANBI's Threatened Species Programme. The fact that a subpopulation of this taxon has been found at a site zoned for development means that its Red List status has to be reviewed and is likely to be upgraded.
Recommendations for species of conservation concern found on proposed development sites
The table below provides guidelines for specialists on appropriate recommendations for species of conservation concern found on a proposed development site. The recommendations differ depending on both the Red List status of the species, as well as the Red List criteria met. Recommendations in the past placed too much emphasis on the Red List category, and not enough on the specific reasons why a species is threatened, and a consideration of which recommendations would best ensure the future survival of the species. The use of IUCN Categories and Criteria (version 3.1, 2001) in this Red List makes it possible to gain an understanding of the reasons why a species is threatened, simply by looking at which criteria were met in the classification of the species.
|Status||Criterion||Guidelines for Recommendation|
|a Please notify the Threatened Species Programme immediately and provide details of the location, size and threats to the subpopulation. The fact that a subpopulation of the species was found at a site zoned for development means that its Red List status has to be reviewed and is likely to be upgraded.|
|aCritically Endangered||PE||No further loss of natural habitat should be permitted as the species is on the brink of extinction, and all other known subpopulations have been lost. The subpopulation in question is likely to be newly discovered and the only remaining subpopulation of this species.|
|Critically Endangered||A,B,C,D||No further loss of natural habitat should be permitted as the species is on the verge of extinction.|
|Endangered||B,C,D||No further loss of habitat should be permitted as the species is likely to go extinct in the near future if current pressures continue. All remaining subpopulations have to be conserved if this species is to survive in the long term.|
|Endangered||Listed under A only||If the species has a restricted range (EOO < 2 000 km2), recommend no further loss of habitat. If range size is larger, the species is possibly long- lived but widespread, and limited habitat loss may be considered under certain circumstances, such as the implementation of an offset whereby another viable, known subpopulation is formally conserved in terms of the National Environmental Management: Protected Areas Act (Act 57 of 2003), and provided that the subpopulation to be destroyed does not occur (i) within a threatened ecosystem or (ii) within an area required for biodiversity conservation in terms of a relevant spatial biodiversity plan or (iii) on a site associated with additional ecological sensitivities.|
|aVulnerable||D||This species either constitutes less than 1 000 individuals or is known from a very restricted range. No further loss of habitat should be permitted as the species' status will immediately become either Critically Endangered or Endangered, should habitat be lost.|
|Vulnerable||B,C||The species is approaching extinction but there are still a number of subpopulations in existence. Recommend no further loss of habitat as this will increase the extinction risk of the species.|
|Vulnerable||Listed under A only||If the species has a restricted range, EOO < 2 000 km2, recommend no further loss of habitat. If range size is larger, the species is possibly long-lived but widespread, and limited habitat loss may be considered under certain circumstances, such as the implementation of an offset whereby another viable, known subpopulation is formally conserved in terms of the Protected Areas Act, and provided that the subpopulation to be destroyed does not occur (i) within a threatened ecosystem or (ii) within an area required for biodiversity conservation in terms of a relevant spatial biodiversity plan or (iii) on a site associated with additional ecological sensitivities.|
|aData Deficient||D||This species is very poorly known, with insufficient information on its habitat, population status or distribution to assess it. However, it is highly likely to be threatened. If a Data Deficient species will be affected by a proposed activity, the subpopulation should be well surveyed and the data sent to the Threatened Species Programme. The species will be reassessed and the new status of the species, with a recommendation, will be provided within a short timeframe.|
|Data Deficient||T||There is uncertainty regarding the taxonomic status of this species, but it is likely to be threatened. Contact the taxonomist working on this group to resolve its taxonomic status; the species will then be reassessed by the Threatened Species Programme.|
|aNear Threatened||D||Currently known from fewer than 10 locations, therefore preferably recommend no loss of habitat. Should loss of this species' habitat be considered, then an offset that includes conserving another viable subpopulation (in terms of the Protected Areas Act) should be implemented, provided that the subpopulation to be destroyed does not occur (i) within a threatened ecosystem or (ii) within an area required for biodiversity conservation in terms of a relevant spatial biodiversity plan or (iii) on a site associated with additional ecological sensitivities.|
|Near Threatened||B,C||The species is approaching thresholds for listing as threatened but there are still a number of subpopulations in existence and therefore there is need to minimise loss of habitat. Conservation of subpopulations is essential if they occur (i) within a threatened ecosystem or (ii) within an area required for biodiversity conservation in terms of a relevant spatial biodiversity plan or (iii) on a site associated with additional ecological sensitivities.|
|Near Threatened||Listed under A only||If the species has a restricted range, EOO < 2 000 km2, then recommend no further loss of habitat. If range size is larger, the species is possibly long-lived but widespread, and limited habitat loss may be considered. Conservation of subpopulations is essential if they occur (i) within a threatened ecosystem or (ii) within an area required for biodiversity conservation in terms of a relevant biodiversity conservation plan or (iii) on a site associated with additional ecological sensitivities.|
|aCritically Rare||This is a highly range-restricted species, known from a single site, and therefore no loss of habitat should be permitted as it may lead to extinction of the species. The Threatened Species Programme is not aware of any current threats to this species and should be notified without delay.|
|aRare||The species is likely to have a restricted range, or be highly habitat specific, or have small numbers of individuals, all of which makes it vulnerable to extinction should it lose habitat. Recommend no loss of habitat. The Threatened Species Programme is not aware of any current threats to this species and should be notified without delay.|
|Declining||The species is declining but the population has not yet reached a threshold of concern; limited loss of habitat may be permitted. Should the species is known to be used for traditional medicine and if individuals will not be conserved in situ, plants should be rescued and used as mother stock for medicinal plant cultivation programmes.|
In addition to recommendations based on status of species found on the site, botanical specialists should include recommendations pertaining to long-term persistence of the species concerned.
Maintaining habitat connectivity
In many cases, a proposed development such as a township development can be accommodated on a site where a species of conservation concern is present. It should be recommended that the subpopulation be conserved in a contiguous natural open space system. This natural area should provide sufficient space for the subpopulation (equivalent to its entire area of occupancy) and a buffer zone of at least 200 m to mitigate deleterious edge effects. In addition, the open space system must be sufficient to conserve pollinators. Connectivity with natural vegetation on adjacent sites should be promoted and habitat fragmentation should be minimised (e.g. by clustering development in the least ecologically sensitive areas).
The need for an Ecological Management Plan
If a development is authorised on a site with species of conservation concern, an Ecological Management Plan for the open space system on the site should be recommended, to be compiled by a suitably qualified specialist as part of the broader Environmental Management Plan, for implementation by an appropriate management authority (such as a body corporate or Section 21 company). The Ecological Management Plan must ensure the long-term persistence of the species of conservation concern, include a monitoring programme for the species, facilitate/augment natural ecological processes such as fire and herbivory, provide for the habitat and life history needs of important pollinators, minimise artificial edge effects (e.g. water runoff from developed areas and application of chemicals), and include an ongoing monitoring and eradication programme for nonindigenous species, with specific emphasis on invasive and weedy species.
Mitigation of impact during construction
Mitigation measures to protect the species of conservation concern during construction should be recommended, for example fencing off the open space system prior to construction. Landscaping with local indigenous species is preferable and could include forage and host plants required by pollinators.
Strong avoidance of ex situ ('search and rescue') options for conserving species of conservation concern
In situ conservation is vital and should be recommended as the only option for conserving species of conservation concern. Ex situ conservation, i.e. the removal of a subpopulation from its natural habitat to an artificial environment, a practice often termed 'search and rescue', will result in the erosion of the inherent genetic diversity and characteristics of that species and increase its extinction risk in the wild. Similarly, translocation of subpopulations is an unacceptable conservation measure. Translocations are expensive and rarely successful. Even if they are successful, translocated individuals may harm other species within the receiving environment, the translocated individuals may transmit pathogens and/or parasites, and translocation may result in rapid changes in the species itself.
What should the final report of the botanical specialist include?
The final report of the botanical specialist should include:
- The date when the botanical survey took place.
- A list of plant species found at the site.
- A list of species of conservation concern found at the site, including those that may be dormant.
- Any limitations of the botanical survey, particularly related to seasonality.
- A clear recommendation on whether to avoid, mitigate, remedy or offset loss of habitat for species of conservation concern as a result of the proposed development (based on the table above).
- Clear recommendations on appropriate mitigation measures, including mitigation during construction, maintaining habitat connectivity, and the need for an Ecological Management Plan.
Recommendations from the botanical specialist have to be summarised in a clear and explicit way in the specialist's report, in such a way that they can be copied into the main Basic Assessment or EIA report and then into the record of decision.
De Villiers, C.C., Driver, A., Clark, B., Euston-Brown, D.I.W., Day, E.G., Job, N., Helme, N.A., Holmes, P.M., Brownlie, S. and Rebelo, A.G. 2005. Fynbos Forum ecosystem guidelines for environmental assessment in the Western Cape. Report prepared by the Fynbos Forum and the Botanical Society of South Africa, Cape Town.
Driver, M., Raimondo, D., Maze, K., Pfab, M.F. and Helme, N.A. 2009. Applications of the Red List for conservation practitioners. In: D. Raimondo, L. Von Staden, W. Foden, J.E. Victor, N.A. Helme, R.C. Turner, D.A. Kamundi and P.A. Manyama (eds). Red List of South African Plants. Strelitzia 25:41-52. South African National Biodiversity Institute, Pretoria.