| Coega Background Briefing |  |
The COEGA HARBOUR and IDZ -- The Eastern Cape's Greatest Environmental Threat
Contents
Billiton, a London-based multinational, are proposing the construction of a zinc refinery at the mouth of the Coega River on the outskirts of Port Elizabeth in the Eastern Cape Province of South Africa. Billiton, and their predecessor in interest Gencor, have also been deeply involved in the design and promotion of a major deep-water harbour to be built at the Coega location. These plans were initially brought to the attention of the South African public towards the end of 1996, and are at an advanced stage.
Billiton’s refinery threatens grave damage to the health and environment of the people of the Eastern Cape. The substantial air pollution, heavy metal contamination and toxic waste that would be produced by the refinery will result in serious public health impacts on the many inhabitants of the area – inhabitants who are largely very poor and without, therefore, the resources to defend their health and well-being. The harbour and industrial development zone that would be built to service Billiton’s refinery would threaten irreparable damage to environmental resources of international importance.
The OECD Guidelines for Multinational Enterprises are clear in requiring enterprises to take due account of the need to protect the environment in the conduct of their activities. Specifically, they require enterprises adequately to assess the impacts of their activities on the environment, and to take full account of such impacts in their activities, in particular with respect to siting decisions. Billiton, in their conduct up to this point, have utterly failed to show the most basic respect for the environment and health and well-being of the people of the area that could be expected of any responsible company.
The assessments of environmental, social and public health impact that have been undertaken to date have been fatally flawed, and have therefore failed to make clear that the proposed refinery location is manifestly unsuitable for a facility of this nature. Billiton seek to take advantage of the region’s desperate need for employment to enable construction of a highly polluting facility that would never be allowed adjacent to a major population centre in the UK or any other European country. The Portfolio Committee on Environmental Affairs and Tourism of the South African National Assembly have investigated the matter and have recommended in a special report that an independent body be convened to consider the objections made to the public participation process used and the conclusions of the expert studies.
Click here for a dateline on how it all began, compiled by Simric Yarrow for SAEP.
Threat of Forced Removals and other Impacts on Neighbouring Communities
The "environment" includes not only the natural environment, but also the human environment, as is made abundantly clear by the express emphasis on human health in the Guidelines. It is difficult to imagine a more profound impact on a human community than forced removal. Such removals were a major instrument of the apartheid government of South Africa. Yet creation of the Coega Industrial Development Zone and Billiton’s refinery threatens local communities with another round of forced removals.
The impacts of the refinery and associated development on the lives and well being of the communities in the area are potentially massive, but have been all but ignored by Billiton. The attached statement by the residents of Coega vividly illustrates the nature and gravity of the problem. The residents of Coega and other communities have not been informed of the potential impacts on them or given an opportunity to assert their interests.
It is still unclear, even now, how many people will actually have to be relocated to allow for the Coega development and the Billiton refinery to proceed. The Coega area is home to a number of communities of varying size and nature. The original social impact assessment was categorical in stating that this problem must be remedied, requiring that "a census which includes basic demographic information, household incomes and assets, must be undertaken in and around Coega Industrial Development Zone, before a decision to proceed is made." This has still not been done.
We submit that the attitude of Billiton to these issues is totally unacceptable. Billiton have taken no steps to remedy the lack of assessment in this respect, even in so far as it relates directly to inhabitants and land-users on the site of Billiton’s refinery. The issue is barely mentioned in Billiton’s Supplementary Environmental Impact Report, produced in June 1998; where it is, Billiton again make it clear that they are washing their hands entirely of this issue. This is again indicative of the nature of this proposed development and Billiton’s approach – one that utterly ignores the consequences that will be experienced by the people of the area.
The fatal deficiencies in the so-called public participation process have been repeatedly called to the attention of Billiton/Gencor. Yet Billiton explicitly seek to wash their hands of such issues.
Billiton’s Supplementary Environmental Impact Report (SEIR) concedes that a number of regional and local impacts are possible, including increased competition for resources from induced migration, increased demand for housing, increased stress on education budgets and schools, lowering of quality of life in surrounding residential, retail and recreational areas, and the potential disruption caused by off-duty workers during construction. The response of the SEIR to such potentially severe consequences of the refinery is extraordinary: "Many of these impacts are existing regional problems which the project might exacerbate, but by virtue of the scale of the impacts, they will not be readily mitigable by Billiton."
This denial of any responsibility is stated with even more clarity in the Response Report attached to the SEIR, where, despite again acknowledging that in-migration will cause problems, no attempt is made to assess the level of those problems, and it is stated that Billiton "cannot take responsibility for relocation in the region. This is a local and regional authority responsibility." (emphasis added.) No justification is provided for this abdication of responsibility.
________________________________________________
Flawed Environmental Impact Assessment Process
The environmental assessment process for the proposed Coega IDZ and Harbour was fundamentally flawed in both concept and execution. The inadequacies are not of form, but of substance, and go to the very integrity of the process and of the result. Environmental impact assessment is designed to enable the decision-maker to make an informed decision. Professor Richard Fuggle of UCT has described the Strategic Environmental Assessment for the IDZ as containing "serious deficiencies" and "not a document that can be used to guide decision makers at a strategic or policy level."
· The time frame for the environmental assessment imposed by Gencor (two and a half months from "scoping" to completion of the studies) was wholly insufficient for a project of this nature and magnitude.
· The "scoping" process - the foundation for the entire assessment - was done over a two-week period that included the Christmas and New Years holidays and involved almost no public participation, resulting in the exclusion of key geographical areas and economic activities (including agriculture and fishing).
· The consultants did not have an adequate project description on which to base their analysis and it could therefore not be effective. They state: "For an Environmental Impact Assessment to be effective, a full description of the proposed project, its objectives, inputs, and outputs and the movement of these, as well as inputs and outputs during the construction phase are necessary. Much of the detail required was not available at the time of conducting the Impact Assessment."(1)
· Key recommendations by the IDZ's own specialists - as well as various interested and affected parties - for important further studies were ignored.
· An Environmental Impact Report (EIR) was not even prepared for the IDZ component; instead a so-called Strategic Environmental Assessment (SEA) was done. Professor Fuggle provides a devastating critique of this document, which he says is "not an Strategic Environmental Assessment as this term is generally understood".
· The public participation process was in fact a public relations process designed not to inform interested and affected parties, but to sell the project. It failed to include many of those who would be most directly affected, including those who may have to be relocated, and did not adequately inform or empower the historically disadvantaged communities to participate meaningfully in the process. SANCO have described the process as "not democratic".
· Misleading information concerning the number of jobs that would be created has been widely disseminated.
· Cumulative impacts of a major industrial development zone designed to attract "dirty" industries were not projected or analysed as is required.
· No analysis was done of whether the project would be environmentally sustainable, with key issues such as how the toxic and hazardous waste to be generated would be stored, treated, or disposed of not addressed.
· Incredibly, no risk assessment (that would address risks both from normal operations and catastrophic accidents such as fires and explosions) was undertaken; such assessments are an essential part of an EIA for a project of this type.
Furthermore, there is concern regarding the independence and objectivity of Billiton’s consultant. South African environmental legislation aims to ensure adequate and transparent assessment of the environmental impact of proposed developments by requiring an environmental impact assessment be undertaken by an independent consultant. Billiton have hired Dr. John Raimondo of African Environmental Solutions, Cape Town, as such an independent consultant. However, Billiton have never revealed to the South African government, the Eastern Cape provincial authorities, or local, community and environmental organisations in the Eastern Cape that Dr. Raimondo also serves as a paid employee of Billiton plc. as a member of their Health, Safety and the Environment committee, and as such is definitively not an independent consultant as required by South African law. More details about this concern here.
Read more about the flaws in the environmental impact assessment process in the SAEP Coega Issues Document here.
________________________________________________
The Coega IDZ Company has provided no economic analysis of whether the proposed IDZ and harbour would in fact be on balance beneficial or harmful. A paper by Professor Stephen Hosking, a senior member of the economics faculty at UPE, found that the economic benefits of the project were in fact very limited and that the economic costs of the development in terms of jobs and income lost or foregone would far outweigh those benefits. An article in the SA Labour Bulletin argued that the Coega IDZ "is unlikely to make any contribution to redistribution and sustainable development in South Africa."
· Only 850 permanent on-site jobs would be created by the identified capital-intensive industrial tenants, most of them skilled jobs for people from outside the Port Elizabeth area. The developers are requesting to be subsidised to the tune of R1.5 billion in public funds to achieve this.
· The development would preclude a planned tourist development proposed near the Coega mouth (Umtha Welanga) that would generate 3 000 jobs.
· The development would lead to the closure of a mariculture operation that will employ 875 people when fully operational, as well as precluding any further mariculture development in a wide radius around the proposed IDZ.
· If the water that planned to be consumed by the Coega IDZ were devoted to agriculture, for which there is ample and eminently suitable land available in the Coega and Sundays River Valleys, over 2 500 jobs would be created.
· The development threatens thousands of jobs in the fishing and agriculture industries. In particular, the development is likely to severely impact on the Logan Braes agricultural project, 2 700 ha of prime agricultural land adjacent to the proposed IDZ boundaries that is currently being developed for emerging black farmers and would employ in the region of 8,000 people, as well as similarly threatening an emerging farmer development project in the Coega River Valley that was proposed in the 1980s but for which water was denied.
· The Coega environmental studies do not analyse comparative development scenarios or provide a basis for decisions as to the economic and environmental sustainability of the development.
Read more about the deficiencies in the official Coega economic analysis in the Coega Issues Document here.
Follow these links for more detailed information on the potentially devastating consequences for the local fishing and agriculture industries.
Also, read a research paper by SAEP official, Clyde Seepersad, which used the method of Social Cost Benefit Analysis to demonstrate that the alternative agriculture-tourism option would be substantially more successful in addressing the key issues of unemployment and poverty in the Eastern Cape.
________________________________________________
Serious Threats to Public Health
The serious threats to public health - especially from air pollution including sulphur dioxide and heavy metals that could be released or blown from the IDZ and Harbour facilities- remain to be adequately investigated.
· Major new research findings indicate that the sulphur dioxide emissions that would be generated by the Coega IDZs tenants could lead to significant increased mortality.
· The sulphur dioxide emissions from the Gencor/Kynoch facilities alone could result in concentrations of this pollutant that exceed the latest UK air quality standards.
· No cumulative assessment of air pollution impacts from an IDZ of this magnitude has been undertaken. As a consequence, there is no information regarding the total levels of pollution that will actually result from the proposed industries. The importance of this deficiency cannot be overstated.
· The SEA made a gross numerical error in reporting one of the key health guidelines. If the correct figure is used, the emissions from the Gencor/Kynoch facility alone would exceed the limits recommended by the IDZ's own specialist consultants, which are designed to reflect the toughest international standards.
· The Coega IDZ's own specialist consultants recommended that further studies were necessary on the levels of emissions from the proposed facilities, along with a health risk assessment. None of this has been done. Instead, Gencor states that it will do a health assessment only after it has selected a site, rather than doing such a study to inform itself and the public as to whether the site is appropriate.
· Inadequate baseline air quality data exist for current pollutant levels and health problems in the Coega area, a key issue given the existence of a polluting brickworks in the area; the limited time frame and mandate given to the consultants did not permit collection of such data in the areas that might be affected by the project.
· Inadequate meteorological data were available to model pollutant dispersal in areas likely to be affected. The level and extent of pollutant dispersal therefore remains uncertain.
Read a summary of the key unanswered questions on air pollution prepared for SAEP by Subho Banerjee.
________________________________________________
Failure to Take Responsibility for Waste Disposal
The OECD guidelines are clear and specific in highlighting the responsibility of enterprises for ensuring the safe disposal of waste generated by their activities. This is particularly important in the context of Billiton’s refinery, which will produce large quantities of toxic effluent and solid waste. Despite this, Billiton are refusing to take responsibility for the safe disposal of the waste generated by their refinery, and have refused to undertake an assessment of the consequences of, and risks associated with, the transport of and disposal of their waste. In addition, Billiton have failed to assess the impacts that would result from the treatment of liquid effluent, an effluent which might contain a number of potentially serious toxins.
The manner in which Billiton have absolved themselves of responsibility for these issues is of the greatest concern in the context in which they are currently proposing to operate. The only site in the Eastern Cape currently able to accept hazardous wastes will be closed in less than five years, and no replacement site has been identified. Billiton are assuming that the South African government will solve this problem. However, there is very serious concern that there may well not be the capacity within both the government and the private sector not only to manage and maintain any waste disposal site, but also to monitor its activities, react in the event of an accident or emergency, and handle any clean-up or remediation activities required. This should be an especially critical point in South Africa’s case, since South Africa has had no previous experience in dealing with an industry of this nature, nor with one that will be producing wastes in such large quantities and with such a high toxicity level. In light of this, it is particularly surprising and unsettling that even though in the EIR it is recommended that a thorough waste disposal study be done, this has still never been done. In the SEIR it states that "…a waste disposal study is not considered essential for Billiton." No further explanation has been given by Billiton for their refusal to undertaken an assessment of the options for, and impacts associated with, the disposal of the waste generated by their refinery.
In order to put this issue into the proper perspective, it is important to highlight the types of impacts that have occurred in other countries when dealing with such wastes and in such quantities. In industrialised countries it is increasingly being recognised that there are far-reaching, long-term, and significant impacts that result from the operation of hazardous waste disposal sites. These impacts have occurred even despite the fact that all the precautions were taken, the sites were lined, the wastes encapsulated, and the run-off contained. It seems it is impossible to mitigate impacts to a negligible level; there will always be some effect. This does not mean that taking these risks is not acceptable - perhaps the benefits of the project do indeed outweigh the negative effects. However, the potential impacts should be taken extremely seriously.
It is therefore not sufficient merely to state, as they have, that "Billiton will not proceed with their project if they are not assured that a suitable waste facility will be available, as they will not dispose of waste in an irresponsible manner". A site may be established, and Billiton may have every intention of using it in a responsible manner, but this does not mean that the impacts will be negligible, or even manageable. A sign of commitment from Billiton to take these issues as seriously as they should be taken would be the commissioning of a detailed waste disposal study. The fact that they have chosen not to do this not only raises some serious questions about both their intentions and their dedication to minimising the impact of this development on South Africa’s environment, but places them in clear violation of the requirements placed upon them by the OECD guidelines.
As well as being unspecified, there are serious concerns that the operation strategy for the ETP outlined by Billiton may not comply with internationally accepted environmental standards. The Production Process Review done by the University of Cape Town’s Chemical Engineering Department states that "we are concerned that the operating philosophy for the ETP, that is one of a ‘catch all’ for non product streams, is not consistent with BPEO [Best Practicable Environmental Option] practice". These specialists further recommended that the design and strategy of the ETP be "completed as soon as possible" so that these concerns can be fully investigated. The fact that this has still not been done is particularly disconcerting. It means that the design cannot be compared against internationally accepted criteria, since it is not known, even at this late stage, what this design is. The SEIR sheds no light on this issue, and only makes the vague and essentially meaningless recommendation to Billiton that "once the project is approved and enters the detailed design phase…the commitment to the BPEO should reflect the exploration of alternatives in the ETP design".
To add to the concerns, the SEIR states that "effluent discharges will be increased by 103 000 m3 annually" from what was stated in the original EIR as a result of the withdrawal from the proposed project of the Kynoch phosphoric acid plant.. This makes the identification of the ETP strategy an even more critical issue. Yet, the impacts of the discharge of treated effluent are only briefly addressed in both the EIR and SEIR. For example, it is stated that "disposal of treated effluent into local rivers will probably have a negative impact", and "with regard to the marine environment, the potential impact of the project could be associated with: discharging treated industrial effluent and treated stormwater into the marine environment". Since further detail is lacking as to what these risks are, however, these negative impacts remain unassessed.
The ETP is an integral part of the zinc refinery scheme as a whole. While its design and the associated impacts remain unknown, the assessment of the consequences of the refinery as required by the OECD guidelines remains undone. Until the ETP strategy has been clarified and the associated impacts established, the levels of contamination from the refinery and the consequent environmental and health risks cannot be known or assessed. This is an entirely unacceptable situation.
________________________________________________
Heavy metals will be the main group of contaminants resulting from the discharge of effluent, as well as occurring due to a number of other zinc refinery operations. The types of consequences that may accrue from the discharge of effluent containing heavy metals must not be treated lightly, especially in an area containing large numbers of residents, in addition to considerable agricultural and marine production. Despite this, Billiton have utterly failed to adequately analyse the levels of heavy metal contamination that will arise from their refinery and the consequent health effects.
The approach that Billiton have adopted is highly cursory. It is stated in both the EIR and the SEIR that "effluents generated by the Zinc Refinery Complex will be treated to specifications lower than the requirements of the PE Municipality or other regulatory bodies". The treatment process to be used will apparently "ensure that heavy metals are precipitated to well within the standards required for industrial effluent". We do not question this here. However, even if all discharge standards are met, and no accidental spills ever occur, there will still be impacts over time. These effects may not be seen during the first few years of operation, but the contaminants will be slowly accumulating in the local environment during this time. Eventually their levels in the soil and surface water may not only be noticeable, but may be a cause for serious concern. The reasons for this are two-fold: firstly, the contaminants in question - heavy metals - are persistent in the environment, i.e. they will not bio-degrade, nor can they easily be "cleaned up"; secondly, many of the contaminants in question have been proven to have negative effects on human health, including causing cancer.
The specific heavy metals that will be present in the treated effluent, according to the production process review, include: mercury, selenium, magnesium, manganese, arsenic, cadmium, copper, lead, nickel, iron, and zinc. Trace amounts of other metals will also be present. Even though the great majority of these metals can be precipitated out of the liquid during treatment so that their quantities will fall within discharge standards, it will be impossible to remove them entirely from the waste stream. Hence, the many years of continual flushing out of effluent into the Reclamation Works, into the local river system, and then finally out into the sea will result in a slow build up of contaminants in the soil beds of these water routes. This impact is unavoidable, and must be seen simply as one of the costs of this particular type of development.
It is not appropriate at this point to go into detail about the effects of trace metal contamination of an environment on the local human and animal populations. Let it suffice to say that some of these contaminants are proven human carcinogens when long-term exposure occurs to doses even in the microgram range. Damage is also known to occur to the kidneys, liver, lungs, stomach, and central nervous system as a result of chronic exposure. The examination and quantification of this risk, however, could only occur if a thorough assessment were made of the cumulative and long-term effects of this project. Merely looking at whether or not Billiton will meet effluent discharge standards, will, of course, not highlight this issue.
In the light of these concerns, it is manifestly clear that it is insufficient for Billiton to state that any effluent discharged will fall within local guidelines. It is essential that a study is undertaken that evaluates the long-term and cumulative impacts of heavy metal contamination, both airborne and from treated effluent. Such a study will need finalised details of the ETP, and must consider the impacts on marine, terrestrial and groundwater environments. A further concern which must be briefly noted is that the monitoring programme outlined in the EIA documents and which the consultants recommend Billiton follow would not even have the capacity to identify these impacts should they occur in the future. Ground water, for example, is to be monitored by regularly sampling six boreholes at the Amsterdamplein site. No provision is made for monitoring the effects beyond the boundaries of this site. This illustrates the manner in which Billiton are refusing to treat these potential impacts with the seriousness that they deserve.
________________________________________________
Irreversible Ecological Damage
Algoa Bay is an especially rich ecological area, in particular the St Croix island group marine reserve. The proposed development poses a number of substantial threats to precious ecological resources.
· Key conditions placed on the location of the harbour by the IDZ's specialist consultants mean that it can be located no closer than 2 000m to the ecologically critical Jahleel Island. There are good grounds for believing that these recommendations will be ignored by the developers.
· The harbour threatens the last stronghold of the African Penguin. The IDZ's own specialist consultant has said that the development "may well deal the species the fatal blow."
· The Algoa Bay islands are the last Southern African habitat of the Roseate Tern, whose continued existence in the sub-continent is therefore critically threatened by the proposed development.
· The harbour would seriously impact on the endangered Humpback Dolphin, and adversely effect the habitat of the Southern Right Whale.
· The proposed IDZ would have a significant detrimental effect on development of the proposed Greater Addo National Park.
Read more about the ecological damage due to the development in the Coega Issues Document here.
It is not enough for the government to pursue strategies which raise GDP and bring in more foreign exchange. Unemployment and poverty are the joint enemies of social upliftment and must be at the forefront of any effort to create the ‘new’ South Africa. It is precisely because it ignores the employment and net income effects on different socio-economic groups that this paper has argued against the traditional cost-benefit analysis, of the kind carried out in evaluating the Coega proposal. What is needed is a tool, such as SCBA, which explicitly puts these concerns at the heart of the decision process.
The analysis presented in this paper shows quite clearly that the preferred project should be the agri-tourism option. Even with the extremely conservative assessment, which treated the multiplier effect of the agri-tourism option as being zero, the employment generated is almost five times that of the Coega alternative. When we look at the total value (i.e. weighted NPV) of the alternatives, the agri-tourism option generates R4.6 Billion, compared to R3.7 Billion for Coega, i.e. it would represent a 25% improvement. More starkly, the positive impact on the poorest section of the community is almost four times as much as for the Coega project.
Read the full text of the paper here.
What is the true air pollution price of the proposed Coega IDZ and harbour project? (Subho Banerjee, November 1998)The importance of establishing the facts about the air pollution impact of the Coega development can not be overstated. Given the proximity of residential communities to the Coega project, air pollution has the potential to have a serious effect on public health, and may even lead to a substantial increase in mortality rates. SAEP believes that approval for the Coega development prior to addressing the questions raised in this paper represents a dangerous game of air pollution Russian roulette.
Read the full text of the paper here.