The Social Impact Assessment Report is fundamentally flawed

By Dr Piet Human

Principle 1 of the 1992 Rio Declaration on Environment and Development states that: “Human beings are at the centre of concerns for sustainable development. They are entitled to a healthy and productive life in harmony with nature.[1]” One would therefore expect that due attention be given in an Environmental Impact Report (EIR) to the social impacts of the proposed nuclear-1 project. This is not the case.

“Often SIA was done as part of EIA, usually badly. Over time, however, the practice of SIA has diverged from EIA because of the growing realisation that social issues fundamentally differ from biophysical issues; that the primary task of SIA should be to improve the management of social issues (rather than to only influence go/ no go decisions)”[2]. The ‘social’ is also inherently complex and dynamic.

The ‘specialist’ asked to do the SIA as part of this EIR is probably the least qualified specialist used by GIBBS. Other specialists (Botanists, ecologists, entomologists, geo-hydrologists, etc) are all highly qualified people (PhD’s and at least MSc’s) who have published as specialist in peer reviewed journals and whose references are respected academics or professionals. The SIA ‘specialist’ has a B (Hons) degree in social work, did some other short courses, used mostly municipal managers as references and has published nothing. This is ironic; giving the most complex issue to the least qualified specialist.

Dr Ilse Aucamp[3] reviewed the Social Impact Assessment. She used the DEAT Integrated Environmental Management Information Series: Review in EIA (Guideline 13). Her report highlights some of the short comings:

  • Seven out of the eleven criteria in the checklist to assess if the specialist complied with the terms of reference of the task was said to be problematic.
  • The technical, scientific and professional credibility of the report is questioned. The use of outdated data (2001 census) and the fact that the report is six years old. She makes the point that social communities change and that such an outdated report is not relevant in 2015.
  • The SIA omitted to refer to the ‘Guidelines for Integrating HIV and Gender Related Issues in Environmental Assessment in Eastern and Southern Africa. This is a new requirement for all large-scale EIA’s in South Africa’.
  • The report does not do a comparative analysis of the three sites nor use recent experiences with large projects such as Medupi to come to any conclusion.

Despite these and other flaws in the report, Dr Aucamp declares that ‘the report meets the requirements of professional practice and competence in the SAI field’. This is surprising.

It can be additionally said that the report is not a professional and competent social scientific analysis of the social impact of a proposed nuclear power station. The methodology used is basically desk research (trawling descriptive data from old data bases) and then doing a few interviews (36 in total; perhaps 12 per site). He attended a few public participation sessions (how many we don’t know) and also ‘talked to a number of other people’ (also not giving us any idea of how many or what types). From such a basis (as a sample), it is not possible to come to any reasonable conclusions regarding the social dynamics and the possible impacts of the proposed project. As it stands now, the SIA report measured by social scientific standards is fatally flawed as a whole.

The exclusion of indigenous groups from the study (at all three sites but especially at Thyspunt and Bantamsklip) is of concern. Free, Prior and Informed Consent (FPIC) is a procedural mechanism developed to assist in ensuring the right of Indigenous peoples to self-determination. It is a concept that gained status by its inclusion in the 2007 United Nations Declaration on the Rights of Indigenous. South Africa is a signatory of this convention.

In conclusion, the IAIA states that “A key difference between SIA and EIA is the increasing focus in SIA on enhancing the benefits of projects to impacted communities. Although the need to ensure that the negative impacts are identified and effectively mitigated remains, also of value is revising projects and ancillary activities to ensure greater benefits to communities”. The SIA report comes to the conclusion in its recommendations that the positive outcome of the project will be: “The most significant positive social impact that may be associated with the proposed nuclear power station development is the provision of electricity and its related linkages to the broader national economy”. In other words, no positive impact on the communities discussed or ensuring ‘greater benefits to the communities’. The report then elaborates on the negative impacts such as the lack of job opportunities for locals, the impacts (conflicts) of the influx of temporary workers and jobseekers, HIV and AIDS, risks associated by nuclear accidents, unwanted births and the potential increase in criminal and other illegal activities. The writer makes no final recommendation.

The Executive Summary of the Revised Draft Environmental Impact Report Version 2 does not reflect the contents of the SAI specialist report or that of the peer review. This is unethical.

It is clear that this report is fatally flawed and that it is of little value to inform decision-makers about the social impacts of the proposed project. I would strongly recommend that this report (as well as the economic and tourism reports) be redone properly. The tourism and economic reports suffer from similar weaknesses as this SIA report.

I have only had time to look at this one report and would request that a further 90 days be given to I&A parties to respond to these reports.

Dr Piet Human has a PhD in Sociology and was a professor at the Graduate School of Business, University of Cape Town until 1996.

[1] Vanclay, F. International Principles For Social Impact Assessment. Impact Assessment and Project Appraisal, volume 21, number 1, March 2003.

[2] See Guidance for the Assessing and Management of Social Impact (2015). International Association for Impact Assessment.

[3] Dr Aucamp should be well qualified and is one of the authors of the International Association for Impact Assessment: Guidance for the Assessing and Management of Social Impact (2015).