Environmental impact assessment (EIA) and identification of risks and aspects: CoE has well defined procedures on early risk assessment of its projects. All projects are screened for their siting (with respect to bioregional plans, development constraint zones, sensitive areas etc.) as well as for other environmental risks. If required under the applicable legal requirements, completion of an EIA is a requirement under the screening processes and is completed as part of the pre-feasibility process required under the staged CAPEX approval processes. Environmental Management Plans (EMPs) are prepared for all such projects. EIAs and EMPs are reviewed by competent authorities as per applicable legal requirements for issuance of Environmental Authorizations and Water Use Licenses for the projects and the approval process also includes public consultation.
For projects which do not require an EIA, a generic EMP has been prepared by the City and the same is followed during their development. The generic EMP includes detailed requirements to be followed by the respective agency (contractors/service providers) on management of waste, vegetation removal, cultural/historical artifacts, hazardous substances, biodiversity, traffic, security, and environmental incidents/accidents, among others.
Implementation of the EMPs is monitored by the environmental and natural resources department (as described below) for all projects as well as by competent authorities.
E&S Policies and Management Systems: CoE has a publicly disclosed environmental policy (last updated in 2013) with seven focus areas – sustainable infrastructure, reduction of pollution, protection of natural resources, water resources, environmental governance, environmental education, climate proofing and energy efficiency. The policy describes the expected outcomes as well as activities to be undertaken by the municipality.
The City also has an environmental management framework (EMF) (of 2007) which guides the policy and strategic decisions for its internal projects, permitting of external projects and serves as guide for external developers. In addition, CoE is guided by the Gauteng Province’s EMF, which was developed to facilitate the optimal use of current industrial, mining land and other suitable derelict land for the development of non-polluting industrial and large commercial developments, protection of critical biodiversity areas, proper integration of ecological support areas and focus on sustainability of development (through energy efficiency, waste minimization and green infrastructure). The focus areas of the CoE’s policy are aligned with the requirements of IFC PSs.
Apart from the above, since 2017, CoE has a specific policy on climate change response strategy and has developed individual climate change response plans for each of the departments. The goals under the climate change response strategy include 25% clean energy (through renewables and energy efficiency), reduction of greenhouse gas (GHG) emissions by 20%, improving local food production (20% to be grown locally), climate resilience in the infrastructure, waste reduction and protection of natural resources. The City has initiated projects on sustainable farming (for local food production), climate friendly parks, solar street lighting and green buildings. The progress on climate goals and response plans is reviewed in the Resilience Forum on a regular basis.
Further, the CoE is in the process of getting its land acquisition policy approved, which will be applicable for any future land acquisition. The policy will be reviewed by IFC to include provisions to address displacement consistent with IFC PS5, especially related to informal settlers.
E&S Organization Capacity: The Environmental Resource and Waste (ERW) department (specifically the Compliance division) is responsible for screening of new projects for their compliance with the policy, EMF as well as requirements of applicable legal requirements and has dedicated staff for this work. The department is also responsible for maintaining CoE’s environmental risk assessment register. The department has compliance and enforcement officers who monitor implementation of identified requirements for both internal projects or assets (like municipal waste landfills) and external projects. In addition to the environmental screening and compliance work implementation, the department plans and develops waste management infrastructure (like waste transfer stations, recycling centers, landfills), parks and cemeteries.
The compliance division of the ERW department also acts as the secretariat for Environmental Compliance Forum, which has representatives of national and provincial departments and CoE’s departments. The forum provides guidance on CoE’s services and monitors implementation of capital projects with respect to environmental approval requirements.
In addition to the implementation of human resources (HR) policies for CoE, the HR department is responsible for monitoring implementation of occupational, health and safety (OHS) procedures responsibilities for employees and third-party workers. For this purpose, the department has been staffed with a safety manager and safety officers for the City.
The water and sanitation department of the municipality is responsible for monitoring the performance of sewage treatment plants (STPs) of the city as well as reviewing compliance of various industries with the applicable effluent standards (before discharge of treated effluent in the city’s sewage system).
The department of environmental health monitors the implementation of the air quality management plan of the city in coordination of various stakeholders (NGOs, industry, community) and issues air emissions licenses for various industries.
In addition, respective departments (e.g. energy, water and sanitation, roads), through their project managers, are responsible to ensure implementation of the EMPs, permits requirements as well as OHS procedures for their respective projects and other operations. The project or site managers are also responsible for providing environmental and OHS training to employees, including contract workers.
Emergency planning and response: CoE has a disaster and emergency department, which is responsible to provide emergency services in the City through a network of fire stations. The department reviews and approves all new buildings/assets of the CoE and internal projects for their fire safety system, emergency response planning and ensures regular drills (in addition the same for external projects).
Monitoring and Review: CoE’s ERW department has a standard operating procedure (SOP) for environmental compliance monitoring and enforcement for internal departments/projects. Under the SOP, all respective departments are expected to (a) have a service level agreement (SLA) with their contractors implement all environmental systems and maintain required environmental documentation; (b) monitor its implementation; and (c) issue penalties for the contractors in case of non-compliances. The compliance and enforcement officers of the ERW department also conduct periodic site visits to ensure compliance with applicable requirements and share reports with head of departments. Similarly, on OHS matters, safety officers from HR department review contractors’ OHS system and compliance both before start of project and during the execution of project. All environmental and/or OHS incidents are recorded and investigated.
All landfill sites of the city are audited internally (by compliance officers) on a quarterly basis and externally (by third party consultants) on a six-monthly basis for their compliance with applicable requirements. Regular testing is conducted for effluent quality at all the STPs (by the water and sanitation departments).
Air quality of the city is monitored through a network of air quality monitoring stations and data is made publicly available as part of South African Air Quality Information System (SAAQIS).
All ongoing CAPEX projects are reviewed in the Environmental Compliance Forum for status of issuance of their permits and any non-compliances.
