Mali Bömeke – Essay for course ENVS1149
For my essay I chose the Lion Smelter project in South Africa, because I find it particularly
interesting to learn more about environmental issues outside of Europe. The project is sited on
consolidated land in Steelpoort Valley, South Africa, which is rezoned for industrial use (chapter 7).
It focuses on water and waste management activities by adding and upgrading waste management
activities. The overall goal is to establish alternatives for the location of a new Tailings Storage
Facility (TSF) in two phases and associated infrastructure.
The earlier mentioned activities include for instance; building new dams, such as a TSF return
water dam (RWD), a storm water pollution control dam (PCD) for the raw materials area, and the
diversion of stream to accommodate the proposed TSF. Another task is the development of a new
slag dump (PCD) while the current slag dump will be deactivated. Additionally, a new service road
will be constructed to the new TSF and the existing slag overland conveyer will be re-aligned. All of
the activities above require environmental authorisation under the National Environmental
Management Act (NEMA), the National Water Act (NWA) and the National Environmental
Management: Waste Act (NEMWA) (see Table 1: Legislative Framework). The given EIA report
gives details about the policy and legislative context by providing documents how the proposed
activity adhere and responds to this context. As seen, it is a relatively big project, which, if
successfully implemented, can upgrade and expand water and waste management systems at the
Lion Smelter Plant.
With regard to the selected development footprint I will now further discuss the factors that
influenced the decision to reach the proposed development footprint (chapter 8, page 73). With the
help of various project alternatives and attributes (as seen in table 8.1 (a) in the EIA) the selected
footprint was justified. But also did comments from authorities and interested and affected parties
(in the following called I& APs) play a role in the documented assessment process which lead the
way to the selection of the preferred development footprint. The footprint selection process
included feedback received from I&APs which was incorporated into the final decision as well.
During the selection process the I&AP database was constantly updated, landowners were notified
and information was provided to I&APs so that they had enough participation in the decision. Some
issues raised by the I&APs during the scoping phase (table 8.3 (a)) are also transparently
documented in the report as well as the response from the EAP (Mr. Jasper Müller). Overall, the
selection process for the site prioritized logistical feasibility and reduced ecological impact. Table 2
clearly shows the selected footprint´s logistical and ecological advantages over site B.
As important as the development footprint are the proposed impact management objectives and
the outcomes. The report provides a detailed plan with management solutions for environmental
impacts, including monitoring and reporting requirements (see table 1).
To summarise the final proposed alternatives and give rationales for the preferred option, we need
to list the no-project alternative (which will be deeper discussed later on), the alternative sites,
technology alternatives and process modifications. The technology alternatives focused on the
analysis of energy efficiency, emissions control and resource consumption of various smelting
technologies. Lastly process modifications were an alternative, such as improved waste
management and water recycling. Other rationales for the preferred option are; low ecological
sensitivity, proximity to existing infrastructure, economic benefits like employment and regional
development and the use of advanced, energy efficient technology. Trade-offs in decision making
were for instance technological feasibility versus cost, because the selected smelting technology
brings a higher initial investment.
, Having previously evaluated alternatives, I will now discuss uncertanties that could affect project
outcomes. I will also talk about assumptions and knowledge gaps in the given EIA process. Some
main assumptions made in the EIA are that the existing environmental conditions will remain stable
(like air quality or water resources). Another one is that the project is expected to adhere to all
South African environmental laws and international best practices. Two crucial knowledge gaps to
mention are the climate change effects on the project and the community acceptance. Changes in
temperature and rainfall could influence the feasibility of the project and long-term public
perception may shift as well. Knowing how to address these uncertainties is helpful. Efficient could
be maintaining open communication with local communities and stakeholders for continuous
feedback. Also important would be regularly monitoring to track and mitigate unforeseen impacts
(of the climate).
In the following I will give a reasoned opinion on whether the project should be authorised, based
on the findings of this EIA. I will also take into consideration some potential benefits and drawbacks
of the smelter project and will take the findings from section 12, 17 and 19. The proposed
developments and environmental impacts, as mentioned earlier, are manageable with mitigation
measures (p. 309-312). Also came the EIA report to the conclusion that the no-go alternative is not
feasible as it would force premature closure of the smelter. Lastly, specialist studies confirm
compliance with legislation (see p. 55-68). Coming now to the potential benefits one must mention.
The project’s economic benefits, such as job retention and regional growth, speak for my approval
(see table 3). Another benefit to add is the support of the local employment and procurement
(LEDET and municipal alignment) (see section 6,12.3 and Appendix 8.4(A)).
In my opinion the project should be authorised and the main reasons are feasibility, regulatory
compliance and socio-economic justification as just described above. The benefits outweigh the
drawbacks and therefore I think the smelter project should proceed under regulatory oversight.
As required by NEMA and the EIA regulations, the EAP’s declaration below verifies the
completeness of the assessment and commitment to ongoing monitoring. Mr. Jasper Müller
confirms that all information in this report is accurate and complete to the best of his knowledge
and that the findings align with legal requirements (see p. 41-51). I&AP comments are included
and specialist recommendations were integrated as seen in table 8.4 (C)-(E). The EAP, Mr. Müller,
commits to ongoing oversight during implementation and EMP conditions will be enforced as well
(see p. 481-484). The full declaration can be read in section 19,page 507).
Strict financial provisioning forms a critical part of the project´s environmental compliance
framework. The breakdown of finances includes four cost categories that are stated in table 3.
Funding and management of finances plays a big role as well. The money comes from Glencore´s
regular operation funds which are ring-fenced. This means that they are legally protected funds
and cannot be used for other purposes than environmental liabilities. This is held in a trust account
and managed by Glencore´s environmental department with independent audits (see p.510). All of
this alligns with the NEMA financial provisioning regulations and DWS best practice guidelines
(these will be further discussed below).
To determine whether best practices are followed in this EIA report for the Smelter project in South
Africa or if improvements are needed, following its key chapters are compared against established
good practices, such as those outlined in FasTips. This will give clarity about alignments with
recommended approaches and potential improvements.
The first aspect I will be looking at will be the consideration of alternatives for location, technology
and design, as well as the “no-go” option, like emphasized by FasTips. This EAI report includes
alternatives for the location of the new TSF, RWD, and PCD, as well as the “no-go” option. To
For my essay I chose the Lion Smelter project in South Africa, because I find it particularly
interesting to learn more about environmental issues outside of Europe. The project is sited on
consolidated land in Steelpoort Valley, South Africa, which is rezoned for industrial use (chapter 7).
It focuses on water and waste management activities by adding and upgrading waste management
activities. The overall goal is to establish alternatives for the location of a new Tailings Storage
Facility (TSF) in two phases and associated infrastructure.
The earlier mentioned activities include for instance; building new dams, such as a TSF return
water dam (RWD), a storm water pollution control dam (PCD) for the raw materials area, and the
diversion of stream to accommodate the proposed TSF. Another task is the development of a new
slag dump (PCD) while the current slag dump will be deactivated. Additionally, a new service road
will be constructed to the new TSF and the existing slag overland conveyer will be re-aligned. All of
the activities above require environmental authorisation under the National Environmental
Management Act (NEMA), the National Water Act (NWA) and the National Environmental
Management: Waste Act (NEMWA) (see Table 1: Legislative Framework). The given EIA report
gives details about the policy and legislative context by providing documents how the proposed
activity adhere and responds to this context. As seen, it is a relatively big project, which, if
successfully implemented, can upgrade and expand water and waste management systems at the
Lion Smelter Plant.
With regard to the selected development footprint I will now further discuss the factors that
influenced the decision to reach the proposed development footprint (chapter 8, page 73). With the
help of various project alternatives and attributes (as seen in table 8.1 (a) in the EIA) the selected
footprint was justified. But also did comments from authorities and interested and affected parties
(in the following called I& APs) play a role in the documented assessment process which lead the
way to the selection of the preferred development footprint. The footprint selection process
included feedback received from I&APs which was incorporated into the final decision as well.
During the selection process the I&AP database was constantly updated, landowners were notified
and information was provided to I&APs so that they had enough participation in the decision. Some
issues raised by the I&APs during the scoping phase (table 8.3 (a)) are also transparently
documented in the report as well as the response from the EAP (Mr. Jasper Müller). Overall, the
selection process for the site prioritized logistical feasibility and reduced ecological impact. Table 2
clearly shows the selected footprint´s logistical and ecological advantages over site B.
As important as the development footprint are the proposed impact management objectives and
the outcomes. The report provides a detailed plan with management solutions for environmental
impacts, including monitoring and reporting requirements (see table 1).
To summarise the final proposed alternatives and give rationales for the preferred option, we need
to list the no-project alternative (which will be deeper discussed later on), the alternative sites,
technology alternatives and process modifications. The technology alternatives focused on the
analysis of energy efficiency, emissions control and resource consumption of various smelting
technologies. Lastly process modifications were an alternative, such as improved waste
management and water recycling. Other rationales for the preferred option are; low ecological
sensitivity, proximity to existing infrastructure, economic benefits like employment and regional
development and the use of advanced, energy efficient technology. Trade-offs in decision making
were for instance technological feasibility versus cost, because the selected smelting technology
brings a higher initial investment.
, Having previously evaluated alternatives, I will now discuss uncertanties that could affect project
outcomes. I will also talk about assumptions and knowledge gaps in the given EIA process. Some
main assumptions made in the EIA are that the existing environmental conditions will remain stable
(like air quality or water resources). Another one is that the project is expected to adhere to all
South African environmental laws and international best practices. Two crucial knowledge gaps to
mention are the climate change effects on the project and the community acceptance. Changes in
temperature and rainfall could influence the feasibility of the project and long-term public
perception may shift as well. Knowing how to address these uncertainties is helpful. Efficient could
be maintaining open communication with local communities and stakeholders for continuous
feedback. Also important would be regularly monitoring to track and mitigate unforeseen impacts
(of the climate).
In the following I will give a reasoned opinion on whether the project should be authorised, based
on the findings of this EIA. I will also take into consideration some potential benefits and drawbacks
of the smelter project and will take the findings from section 12, 17 and 19. The proposed
developments and environmental impacts, as mentioned earlier, are manageable with mitigation
measures (p. 309-312). Also came the EIA report to the conclusion that the no-go alternative is not
feasible as it would force premature closure of the smelter. Lastly, specialist studies confirm
compliance with legislation (see p. 55-68). Coming now to the potential benefits one must mention.
The project’s economic benefits, such as job retention and regional growth, speak for my approval
(see table 3). Another benefit to add is the support of the local employment and procurement
(LEDET and municipal alignment) (see section 6,12.3 and Appendix 8.4(A)).
In my opinion the project should be authorised and the main reasons are feasibility, regulatory
compliance and socio-economic justification as just described above. The benefits outweigh the
drawbacks and therefore I think the smelter project should proceed under regulatory oversight.
As required by NEMA and the EIA regulations, the EAP’s declaration below verifies the
completeness of the assessment and commitment to ongoing monitoring. Mr. Jasper Müller
confirms that all information in this report is accurate and complete to the best of his knowledge
and that the findings align with legal requirements (see p. 41-51). I&AP comments are included
and specialist recommendations were integrated as seen in table 8.4 (C)-(E). The EAP, Mr. Müller,
commits to ongoing oversight during implementation and EMP conditions will be enforced as well
(see p. 481-484). The full declaration can be read in section 19,page 507).
Strict financial provisioning forms a critical part of the project´s environmental compliance
framework. The breakdown of finances includes four cost categories that are stated in table 3.
Funding and management of finances plays a big role as well. The money comes from Glencore´s
regular operation funds which are ring-fenced. This means that they are legally protected funds
and cannot be used for other purposes than environmental liabilities. This is held in a trust account
and managed by Glencore´s environmental department with independent audits (see p.510). All of
this alligns with the NEMA financial provisioning regulations and DWS best practice guidelines
(these will be further discussed below).
To determine whether best practices are followed in this EIA report for the Smelter project in South
Africa or if improvements are needed, following its key chapters are compared against established
good practices, such as those outlined in FasTips. This will give clarity about alignments with
recommended approaches and potential improvements.
The first aspect I will be looking at will be the consideration of alternatives for location, technology
and design, as well as the “no-go” option, like emphasized by FasTips. This EAI report includes
alternatives for the location of the new TSF, RWD, and PCD, as well as the “no-go” option. To
