Public Participation Guide: Sasol Natural Gas Project, Mozambique and South Africa

Overview

This case study describes the public participation component of an environmental assessment process related to the development of a natural gas pipeline from Mozambique into South Africa. The project, which was subsequently implemented, involves the extraction and processing of natural gas in Mozambique and its piping to South Africa where it is used by Sasol, a major petrochemical company. The environmental assessment process for the project was wide ranging and so extensive that it necessitated being broken into seven separate environmental assessment processes. The case is of interest because of its scale and complexity, involving two countries and very diverse social and environmental conditions.

Sponsoring Agencies

Mozambique Ministry for Coordination of Environmental Affairs
South Africa Department of Environmental Affairs and Tourism
Mpumulanga Province (South Africa) Department of Agriculture, Conservation and Environment
Sasol (a petrochemical company)

Background

The Sasol Natural Gas Project involves the extraction, processing and effective use of natural gas reserves in the Inhambane Province of Mozambique. It includes the exploration and development of the gas fields, the establishment of a Central Processing Facility at Temane, and the construction of an 865km (nearly 538 miles) cross-border pipeline between Temane in Mozambique and Secunda in South Africa.

The environmental assessment process took place in a context of diverse social conditions, ranging from sophisticated, cosmopolitan and highly diversified economic and social conditions to isolated, underdeveloped and traditional conditions. From a public participation perspective the diversified conditions were such that a highly differentiated participatory process needed to be designed and implemented.

Public Participation Goal and Level

The public participation process was performed in the context of an environmental impact assessment process, the goals of which were to:

Fully explore the environmental, social and economic impacts of the proposed natural gas project;
Assist in the determination of the location of the final pipeline route;
Understand the possible consequences of the pipeline and identify mitigation and enhancement measures;
Incorporate the issues and concerns of affected stakeholders;
Meet the requirements of the range of relevant international and national laws, as well as company and multi-lateral organization policies on environmental assessment; and,
Seek the approval of the relevant decision-making authorities for the proposed project.

The stages through which the environmental assessment proceeded in Mozambique and South Africa contained similar elements, but differed in certain respects. These will be discussed in the public participation approach below.

Given the trans-boundary nature of the pipeline, this project involved a range of public participation goals. These included:

Identifying and involving all relevant stakeholders;
Designing and implementing the public participation process so that it was appropriate to the diverse socio-economic conditions found along the entire route of the project;
Identifying and responding to stakeholder concerns and issues; and,
Aligning the public participation process with parallel processes of negotiations on land issues.

The highest level of public participation sought was the Involve level (see the spectrum of public participation (1 pp, 755 K, About PDF)).

Public Participation Approach

The approach to public participation in Mozambique and South Africa differed based on differing conditions between the countries. In Mozambique, the process placed greater emphasis on reaching out to the rural society in which the gas field and associated pipeline were to be located. In addition, it sought out the involvement of high level actors from national, provincial and district governments. In South Africa, the process stressed the involvement of high-level actors at the national and provincial levels, with an associated process for engaging with land owners along the proposed pipeline route.

A key design issue faced by the project team at the outset of the project was whether to propose – and allow for public input on – a range of alternative pipeline corridors. Project designers concluded this would introduce such a wide range of variables that would make the project impossible to manage. Instead, the project team, with the concurrence of the national departments within the respective countries, selected a single corridor within which the assessment of a possible pipeline would occur. In South Africa, this concurrence was achieved through a pre-screening document that was shared with high-level stakeholders. These stakeholders were informed about the process leading to the selection of the corridor and were told that corridor issue would be reopened for discussion if stakeholders raised any fundamental concerns. None was raised.

In Mozambique the process involved the following stages of activity:

An internal process was conducted in cooperation with the Ministry for the Coordination of Environmental Affairs and other government departments to develop a Scoping Plan to determine the nature and extent of the environmental assessment. This provided the basis for the subsequent implementation of the environmental impact assessment process.
A phase followed in which the environmental impact assessment process was publicly announced and workshops and meetings were conducted in Maputo and at Provincial and District levels outside of the capital. During these meetings the public was asked to identify issues of concern. These activities led to the formulation of a document by the project team which synthesized key issues.
There followed processes to identify needed specialist studies in coordination with the Ministry, and the subsequent appointment of specialists.
Following the completion of the specialist studies, a draft of the Environmental Impact Report was prepared and placed into the public domain for comment. This was associated with public hearings/meetings.
Following this, a final report was prepared and submitted to the Ministry for a decision.
Once the Ministry reached a decision it issued a Record of Decision.
The process concluded with the drafting of an Environmental Management Plan for the design, construction and operation of the project.

In South Africa, the following public participation activities were performed:

An initial exercise of screening possible options for the corridor in which the pipeline would be located was undertaken by the environmental consultants working together with the project engineers. The result of this exercise was discussed with key high-level stakeholders in an invitation-only meeting (this was part of the pre-screening process discussed previously).
Thereafter a Draft Corridor Screening Report and a Scoping Plan were submitted to the Department of Environmental Affairs and Tourism, which gave the go ahead for the subsequent scoping process.
A scoping exercise was then undertaken which involved the following activities: a public announcement of the exercise; public and authority open house events; the synthesis and initial assessment of key issues as well as the preparation of terms of reference for a subsequent environmental impact assessment; and, the preparation and submission to the authorities of a draft Scoping Report. The report was subsequently approved, giving rise to the next stage of the process.
A process then followed in which specialist studies were undertaken and a draft of the Environmental Impact Report was prepared and placed in the public domain for comment. All comments received were synthesized and the draft report amended to reflect the comment.
The revised Environmental Impact Report was consequently submitted to the Department for approval.
Following approval of the report an Environmental Management Plan was prepared.

Specific Public Participation Tools and Techniques Used

The public participation process made use of the following tools and techniques across Mozambique and South Africa:

Key stakeholder and authority workshops;
Public open houses (with graphic and other displays and demonstrations);
Public meetings;
In-person meetings;
Community meetings and focus group discussions with local government and community
leaders, non-governmental organizations and influential people in the study area;
Semi-structured interviews with local leaders, farmers, fishers, hunters and other community role players;
Formal questionnaire surveys; and
Distribution of background information material.

The public participation process provided stakeholders with information about the project as well as opportunities to provide input. In both South Africa and Mozambique, announcements were made about the location of reports and venues for public meetings on the local radio and in the national and local press. Stakeholders were also notified by mail to review reports. Notices were posted on the pipeline route. Full sets of reports were provided to key stakeholders and information was made available to landowners, communities surrounding the pipeline and associated infrastructure, and other stakeholders at different stages throughout the process. Full details of the environmental impact assessment reports were placed on the Sasol website.

Public meetings were held during the course of the process. In South Africa, there was a single initial meeting with a select group of stakeholders, followed by a series of open house events which addressed the draft impact report. Attendance at the latter was poor. This was due to most of the key national stakeholders being satisfied with written correspondence concerning the project. Local stakeholders were primarily farmers who were directly engaged through the land negotiation project and were thus satisfied with the negotiations as the means for their involvement. In Mozambique, public meetings were held in each of the provinces affected by the pipeline. There was varied participation in these while relatively good numbers attended; however, the meetings were conducted in Portuguese and so excluded a large proportion of the population.

Public Participation Strategies in Mozambique

In Mozambique, a national Project Liaison Committee was established at central Government level. It met monthly and was briefed by the project consultants. Stakeholders were identified early in the process and were kept informed during the course of the studies. Open house/public meetings with graphic displays were held in a number of venues along the pipeline route and at the gas field. Transportation was provided to local and provincial government officials to attend these meetings.

A core issue faced by project planners was the distinct characteristics of the communities and stakeholders involved. There were a great number of stakeholders spread over a very long distance (approximately 100 000 people spread over 565 kilometers of the proposed pipeline and gas field). These included 6 towns, 10 villages, and 85 small villages, all with diverse cultures and needs.

Issues associated with language and culture posed challenges for the design and implementation of the public participation process in Mozambique. Portuguese was the primary language within which public activities were undertaken; however, this raised concerns regarding its practicality, given that numerous stakeholders would not be sufficiently conversant in the language to participate in activities. Nevertheless, consultants who convened the process believed it was impractical to conduct the process in the local languages given the large number of languages present. Project reports were prepared in English, which posed a further problem for Mozambican government officials who required them to be translated into Portuguese in order for them to reflect and comment on them.

A number of traditional cultural issues emerged due to the nature of the communities engaged in the process. The process was sensitive to these, particularly the social impact assessment activities. Local community members raised a fundamental concern that the graves of their ancestors would be disturbed by the proposed pipeline. Through a process of consulting with traditional healers, the matter was addressed and a means found for addressing the concern.

Another fundamental issue concerned the capacity of stakeholders to be actively involved in the assessment process. Not only were they unfamiliar with such processes, but in many cases they also lacked the material means to become actively involved. This included not having the means to cover the costs of transport to get to meetings or accommodation where this was necessary. It was soon discovered that representatives of government were using their personal funds to enable stakeholder participation. As a result, Sasol agreed to cover the costs associated with their participation in the process, either through providing them with a lump sum amount to cover their expenses, or through making the necessary arrangements for their transport, accommodation, and subsistence.

A further area of limited capacity was the limited knowledge that stakeholders had about the environmental assessment process and the substantive issues involved. This proved to be the primary reason why there was very little comment on the process and suggestions about making changes to it. While great effort was taken at the initiation of the process, notably by Sasol, to inform stakeholders about the proposed pipeline, many were unfamiliar with the technology and it required careful explanation, particularly for isolated rural communities.

A fundamental part of the environmental assessment process was the social impact assessment process. Undertaken by Mozambican sub-consultants, the exercise was strongly based on the participation of community level actors. The assessment involved two surveys. One was a quantitative survey, while the second was a set of qualitative interviews with different categories of stakeholders. These were particularly important as they involved people who did not participate in the public meetings. Many of those interviewed were not literate or did not read or understand Portuguese, and consequently could not read meeting announcements. Two persons who knew local languages and cultures were trained to conduct relatively informal interviews with local stakeholders. The results of these discussions were fed into both the public participation and the social impact assessment exercises. The social impact assessment consequently had the effect of deepening the involvement of the public and stakeholders in the environmental assessment process.

The public participation process also included a specialist study on socio-economic issues. Within this exercise, approximately 270 families in 12 villages were interviewed who lived in close proximity to the proposed gas fields. Along the pipeline route, 287 households were interviewed during the environmental impact assessment in 24 villages. Semi-structured interviews were carried out with key people in the communities including traditional and religious leaders, farmers, businesspeople, fishers and other key members. The discussions centered on issues of concern to communities that would possibly be affected by the pipeline and the gas fields. Other information was sought, such as community knowledge about the location of important cultural and sacred sites in proximity to the pipeline and gas field infrastructure.

Public Participation Strategies in South Africa

In South Africa, there were far fewer stakeholders involved than in Mozambique. These stakeholders fell into roughly three categories: 1) high level stakeholders within the national and provincial levels of government, as well as key large-scale civil society organizations such as environmental non-governmental organizations, 2) the general public, especially those who had been involved in previous similar projects in Secunda and Sasolburg, and 3) a targeted group of landowners along the proposed pipeline route. Stakeholders were identified through initial consultations and the public was invited to participate in public meetings through newspaper advertisements. Stakeholders were notified by mail about the process, and about the availability of reports. After an initial workshop held with key stakeholders including government and nongovernment participants, open houses were held in various venues along the route and around the affected sites.

Since the South African section of the pipeline is routed almost exclusively in privately owned land, communication with landowners was an important part of the study. Personal visits to these landowners for the purpose of right-of-way easements were conducted. Documentation about the project was distributed directly to farmers affected during the scoping and specialist study phases of the environmental impact assessment. A Draft Environmental Impact Report was distributed and personal communication with key stakeholders was undertaken. Stakeholders were given the opportunity to comment on this report.

Result/Outcome

One measure of the overall success of the public participation effort was that stakeholders raised no major objections to the process.

The primary challenge faced in this participation process was to design and implement a process that would not only deal with a large linear project, but would also accommodate highly diverse stakeholder groups. The approach adopted of sub-dividing the project into various parallel environmental assessment processes contributed significantly to finding a solution. Within each of the processes, diverse approaches and techniques were adopted that were suitable for, and encouraged the participation of, the highly differentiated participating groups.

The process led to certain distinct benefits accruing to stakeholder groups, including:

Stakeholders had the opportunity to both grow their experience in environmental assessment processes, as well as expand their capacity to participate in such processes in future;
The process led to many stakeholders being introduced to debates on the relationship between the Sasol Natural Gas Project and the broader political economy of the two countries involved; and,
The many issues of concern raised by stakeholder groups were either directly addressed through the environmental assessment process, or indirectly through parallel processes.

The participation process also provided the added benefit of deepening civil society participation, notably within Mozambique which at the time was in the process of consolidating its democratic processes after years of colonization and subsequent civil war.

Lessons Learned

This highly complex project provides a number of lessons regarding the design and implementation of public participation processes for trans-boundary projects. Key lessons include:

Specialist studies can play a very significant role in mobilizing stakeholder participation, as well as creating diverse and imaginative mechanisms for their substantive involvement.
Caution needs to be taken in the selection and use of specific languages within environmental assessment processes as this can either facilitate or exclude the participation of key groups. The use of Portuguese as the main language of the process in Mozambique is a case in point.
The process was useful in identifying the value of adopting distinct and diverse approaches employed in involving divergent groups. A “one size fits all” approach cannot be adopted in cases where the character and conditions of stakeholder groups vary markedly.
It is important to recognize and address capacity constraints to stakeholder involvement. In this case, direct material assistance was given to stakeholders which allowed them to participate, where they might otherwise not been in a position to do so.

In addition, there are lessons with respect to the efforts of the primary project sponsors (Sasol and the governments of Mozambique and South Africa, respectively).

Sasol views stakeholder engagement as a fundamental aspect of its operations and not something to be taken lightly or cavalierly. Its philosophy is that failure in the field of stakeholder engagement would be considered a general failure for the company. As a result, it established an “interface” with all stakeholders upon establishing an office in Mozambique. It also built its approach on best practices and prior experiences, by reviewing and embracing World Bank documentation on stakeholder engagement. This overall approach alerted the company to the range of dynamics associated with its stakeholders, appropriate communication strategies and approaches, and established a climate in which stakeholders perceived the company and its initiatives in a positive light.

The government of Mozambique created environmental assessment regulations in 1999, but these where still new when the Sasol project was initiated and did not include any details on what was required in terms of public participation. The Mozambican government demonstrated a willingness to learn and adopt best practices, and so reached out to and developed its public participation approach based on input from the South African Institute for Environmental Assessment and the Netherlands Environmental Assessment Institute. Furthermore, the Mozambican government was able to manage the roles of being both a promoter of development and a regulator.

The government of South Africa conducted public participation activities on a separate track from landowner negotiations. This allowed for a negotiated process with landowners prior to the government being required to reach a final decision and prevented landowners from being coerced by a prior government record of decision.

For more information and source material, see: https://www.eia.nl/docs/mer/diversen/053-028_eia_temane_pande.pdf. (35 pp,158 K, About PDF)

Explore the full Public Participation Guide.

Contacts

For additional information on EPA's Public Participation Guide, contact:

Shereen Kandil
U.S. Environmental Protection Agency
E-mail: [email protected]