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Appendix
C
Preparing EIA Submissions
There are two sequential types of formal EIA submissions which represent
progress reports to meet the requirements of Malawi's EIA process. These
are Project Briefs, and EIA Reports.
C.1 PROJECT BRIEF
A Project Brief is a short report informing DEA that a prescribed activity
is being considered. Its sole purpose is to provide sufficient information
to allow DEA to determine the need for an EIA based on screening criteria
discussed in Appendix D of these guidelines. Thus, a Project Brief must
contain the information needed by DEA to evaluate the report against the
screening criteria.
Unless a project is likely to have evidently significant environmental
impacts, project developers should be able to prepare a Project Brief with
little or no assistance from environmental specialists. Since projects
and their stage in the project cycle varies widely, detailed guidelines
for the content of a Project Brief are not possible. However, Section 24
of the EMA requires that a Project Brief should at least state:
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the nature of the project;
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the activities that shall be undertaken;
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the possible products and by-products anticipated;
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the number of people the project shall employ;
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the area of land, air or water that may be affected; and
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any other matters as may be prescribed. More generally, a Project
Brief should also contain:
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A basic description of the project purpose, size, location and preliminary
design, including any alternatives which are being considered (ea. site,
technology, construction and operation procedures, handling of waste).
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The stage of the project in the project cycle.
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A location map of the project site or site alternatives, and a site plan
as it is currently known. Maps and plans should conform to the standards
discussed below.
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A discussion of which aspects of the project are likely to cause environmental
concerns, and of proposed environmental management measures.
C.2 GENERAL REQUIREMENTS OF AN EIA
REPORT
Section 25 of the EMA contains a specific list of topics that must be
covered in an EIA report. The intention of this appendix is to elaborate
on those topics to give a fuller appreciation of what an EIA report should
contain. Additional topics are also discussed to fill out the contents
of the highest quality of report.
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Quality Standards: Project developers and
their EIA teams should be mindful that an EIA will be evaluated by EAD
using standard, comprehensive evaluation criteria discussed in Appendix
H of these guidelines. Thus, the criteria embodied in these guidelines
represent quality standards which EAD expects project developers to meet
in preparing an EIA report.
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Terms of Reference: The terms of reference
under which the EIA was prepared should be included in the report, usually
as an appendix.
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Identification of the EIA Team: An EIA report
should contain a listing of all the team members involved in preparing
the report, their qualifications in summary, and an overview of what each
member contributed to the report preparation.
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Discussion of EIA Methods: The methods
used in carrying out an EIA should be documented in an EIA report to assist
reviewers in understanding the results and how they were obtained. These
methods include those for identifying potential impacts (ea. checklists,
interaction matrices), for collecting data and information (ea. field surveys,
public consultation), and for analyzing impacts and assessing their significance.
It is especially important in EIA to make the distinction between
the severity of an impact (ea. its magnitude, a real extent, duration,
frequency and reversibility) and its significance. This is a fundamental
distinction which is often overlooked. Assessing the significance of an
impact involves combining information about its likely severity and about
the importance of the environmental feature being affected. In other words,
impact analysis deals with the question What's so?" or is likely to be
so. Impact significance deals with the question "so what?". Decision-makers
need to know the answer to both questions. When methods are unclear and
the distinction between severity and significance are blurred, the usefulness
of EIA results to decision-makers is substantially diminished.
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Public Consultation: The methods and results
of consulting the public should be documented.
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Information and Mapping Standards: All
sources of data and information used in an EIA should be suitably documented.
Secondary sources should be acknowledged and properly referenced. Where
the relevance of the information for EIA purposes may be debatable, the
EIA should justify its use with a discussion of its quality, currency and
precision. The EIA should also identify data and information gaps and analyse
their effect on the study results and reliability.
Other than small-scale location maps, all maps presented in an EIA
Report should be at 1:50,000 or larger scale. All maps must be drawn to
scale with the scale given. Thematic information (ea. roads, streams, and
vegetation types) should be mapped using standard symbols identified in
a legend.
C.3 STRUCTURE OF AN EIA REPORT
The typical elements of an EIA report are presented below. While the
discussion refers to "sections" of a report, those that prepare an EIA
should not feel constrained by the suggested structure but use one which
best communicates the project and the EIA results. In terms of content,
however, an EIA report should contain material discussed below.
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Executive Summary: This is a short but
comprehensive summary of the report, with an emphasis on expected impacts
and management measures. In most cases, the summary should be no more than
two or three pages long.
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Introduction: The introduction will
identify the type of project proposed (ea. a multi-purpose dam), its location
(or location alternatives) and if the project is part of a larger proposal.
The project developer must be clearly identified as must be the team which
carried out the ELA. It will outline the background to the project and
the reasons or necessity for it.
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Project Description: The project description
will indicate the status of the project in the project cycle -- e.g. pre-feasibility,
feasibility, detailed engineering and design -- so that the level of detail
and available planning or design options can be understood by reviewers
of the report. The description of the project and its alternate sites,
designs and implementation strategies will be given in only enough detail
so that impact forecasts and management measures can be understood and
appreciated. Detailed descriptions of aspects of the project irrelevant
to the forecasting and management of impacts must be omitted. In most cases,
it is not necessary to include detailed process or market-sensitive information
which a developer might want to remain confidential. In most cases, the
description will include:
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inputs (raw materials), outputs (products), processes and major types of
equipment;
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maps, flow diagrams and photographs where necessary; and
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a summary of technical, economic and environmental features essential to
understanding the project.
The possible project options available within the existing economic, technical
and environmental constraints will be discussed and compared. These could
be options in terms of size, site, technology, layout, raw materials, energy
sources and even products. The principal features of each option will be
given and the economic, technical and environmental advantages and disadvantages
of each option will be discussed and evaluated. Reasons for selecting the
preferred option(s) will be given.
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Environmental Planning and Design: The
report includes a discussion of the environmental planning that has gone
into the project. All the issues that have been taken into account for
avoiding or minimizing impacts, for capturing potential benefits, for compensating
for residual impacts, and for impact management are discussed.
The design management features to which the developer is committed
are highlighted as these form a key part of the project design on which
impact analysis is carried out. The design process should pay particular
attention to human health issues.
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Public Consultation: The report discusses
the objectives, methods and results of public consultations during the
EIA.
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Environmental Setting: Most importantly,
the report contains a description of the environmental setting. This is
given in only enough detail to allow for an understanding of the analysis
and assessment of impacts. It describes at least the following:
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the spatial and temporal boundaries within which the environmental setting
was considered;
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the existing condition of the physical, biological and human environments
of the project area, as well as trends and the anticipated future environmental
conditions should the project not go ahead; and
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environmentally-sensitive areas of special or unique biophysical, socio-economic
or cultural value.
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Assessment of Environmental Impacts: A description
of how beneficial and adverse impacts, both direct and indirect, are expected
to occur is necessary for each feature of the environment identified as
important during the scoping of the study requirements. Possible cumulative
and synergistic effects are highlighted. In each case, the report
discusses:
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the source(s) or cause(s) of the impact;
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the severity of impact (ie. its magnitude, areal extent, duration, etc.)
as well as the likelihood of its occurring as forecast;
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the assessed significance of the impact; and
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possible measures for avoiding or mitigating the impact
It is imperative that the analysis of impacts be based upon
a comparison of future environmental conditions with and without the project.
Comparison of project-induced changes to existing conditions only is not
acceptable.
The section includes a discussion of the analytical methods used to
forecast impacts, of how environmental data was gathered, and of the methods
and criteria used to judge impact severity and significance.
This section of the report concludes with a summary of those impacts
considered to be of greatest significance and measures proposed to avoid,
reduce and/or manage them. It also discusses the distribution of-adverse
and beneficial impacts locally and regionally. It identifies which impacts
the developer is committed to managing during project implementation and
which are residual impacts -- i.e. those which cannot be avoided or minimised.
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Environmental Management Plan: This
section summarises the earlier discussion of the planning and design measures
that have been adopted into the project plan to reduce or eliminate potential
impacts. It presents a plan for monitoring and managing impacts during
project implementation, and outlines which activities will be undertaken
by the proponent and which should be the responsibility of government.
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Resound Evaluation: Where possible,
the report includes an economic evaluation of the environmental costs and
benefits of the project, and identifies those which cannot be evaluated
in monetary terms. The distribution of costs and benefits (i.e. Who benefits?
Who pays?) is also discussed.
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Summary and Recommendations: Appropriate
conclusions should be drawn in each section of the EIA report. It is useful
to have the conclusions summarised in a series of brief statements referring
to relevant sections of the report. The section focuses on significant
impacts, the measures recommended for avoiding or minimising them, and
the impact management proposals during project implementation.
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Appendices: Appendices contain information
not directly useful in the text of the report but needed for reference
or detailed review by technical experts. These could include:
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The terms-of-reference for the EIA.
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Sources of data and information. All individuals and agencies consulted
for specialist information or knowledge used in the report are referred
to in the text and documented here. Written opinions received from outside
specialists may also be appended. Field data collection programmes completed
during the EIA are also described.
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Detailed data reduced for use in the main body of the EIA report.
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Detailed technical analyses of particular impacts (e.g. pollution dispersion,
soil erosion, projections of demands for social services).
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A summary of the programme for consulting the public in project planning
and assessment, plus a complete record of all parties consulted.
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Names, qualifications and roles of the team members who carried out the
study.
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