Ecosystem Guidelines for Environmental Assessment

INCLUDING BIODIVERSITY CONSIDERATIONS IN PRE-APPLICATION PROJECT PLANNING
TAKING A PRO-ACTIVE APPROACH
Charl de Villiers
Why take a pro-active approach
Early reference to these ecosystem guidelines and to available systematic biodiversity plans (see Table 2)
in the pre-application stage of project development can support informed planning and decision-making
while helping to timeously 'iron out' obstacles that might otherwise result in delays and additional
costs to the project proponent. The pro-active emphasis on pre-application screening is consistent with
the Western Cape Department of Environmental Affairs and Development Planning's (DEA&DP) Guideline
for involving biodiversity specialists in EIA processes: Edition 1 (Brownlie 2005).
Such a pro-active approach can:
Show the decision-making authority that potential conflict between biodiversity priorities and other
land-uses has been identified and resolved by well-informed project planning;
Allow the proponent to take an informed decision about the biodiversity (and administrative and, by
implication, financial) risks of proceeding with a particular project; and
Identify the scope, type and intensity of environmental assessment that is likely to be required if an
application were to proceed.
This approach also supports best practice in environmental assessment and planning by:
Ensuring that a project is consistent with the 'Duty of Care' principle (i.e. that the project proponent
has taken reasonable measures to prevent significant degradation of the environment);
Emphasising the fundamental role of alternatives in selecting the best practicable environmental
option;
Giving effect to the mitigation hierarchy, or the sequential avoidance, minimising and remedying of
impacts that may result in loss of biodiversity or disturbance to ecosystems; and
Supporting the principle that environmental management must pay specific attention to planning
procedures pertaining to sensitive, vulnerable, highly dynamic or stressed ecosystems.
The credibility of this approach is strictly premised on site visits as an essential component of preapplication
biodiversity screening. Without ground-truthing and accurate reporting, biodiversity
screening that relies solely on reference to biodiversity maps and plans must be viewed as incomplete
and therefore inadequate for the purposes of informed decision-making.
Environmental assessment practitioners without the appropriate biodiversity expertise should not
resort to the approach advocated here as a substitute for specialist knowledge and review. Early
appointment of a knowledgeable biodiversity specialist is strongly advised, especially where projects
may be undertaken in Critically Endangered, Endangered or Vulnerable ecosystems.
There are several examples of pro forma terms of reference or guidelines for dealing with biodiversity
in environmental assessment and planning:
The most recent is the DEA&DP's biodiversity guideline (Brownlie 2005), which should be seen as
complementary to these guidelines.
COLIN PATERSON-JONES
14 : TAKING A PRO-ACTIVE APPROACH