Gaps and Uncertainties in Identification of Pressures:

• little experience with proposed technology, so actual pressures it will exert are rather unclear;
• uncertain as to actions of individuals and groups in informal sector, in response to introduction of the proposed technology;
• large amount of gypsum produced - use/disposal options unclear;
• lack of information on what actions will be taken to reduce fugitive emissions, and what pressures will arise.

Gaps and Uncertainties in Identification and Evaluation of Impacts:

• impacts on environmental and human systems not well understood - especially impacts on the informal sector;
• indirect environmental and social impacts of plant during construction, operation and decommissioning not well known.

Gaps and Uncertainties in Evaluation of Alternatives:

• difficult to compare a relatively unproven technology with well established technologies;
• first three alternative options that could be used should be studied more carefully if any concerns regarding the proposed technology are identified during the EIA.

Gaps and Uncertainties in Assessing the Economic Performance

• relatively unproven nature of the technology makes economic evaluation very difficult - from construction, through operation to decommissioning.
• high uncertainty regarding possible changes in domestic regulations and international environmental agreements as well as in international lead prices..

• impacts on social and local natural environmental systems during construction, operation and decommissioning - especially impacts that may arise during collection, storage, and transport of the batteries, and impacts on the informal sector as a result of setting up the plant;
• impacts of the various use/disposal options for the gypsum by-product;
• occupation health and safety impacts;
• impacts of 24 h operation of the plant, including nuisance and safety issues;
• contamination of land and surface and groundwater, including after the plant is decommissioned

• training of staff regarding occupational health and safety issues;
• improved consultations with opinion leaders in informal sector, and raising awareness of opportunities to be productively involved in the battery collection and reprocessing operations;
• development of an effective environmental management system, including impact monitoring and preparation and implementation of impact reduction and mitigation strategies;
• development of a comprehensive national strategy on sustainable management of lead.

Many of the potential pressures and associated impacts on environmental and human systems have been identified and described. The remaining shortcomings are primarily related to three factors: i) the proposed technology is relatively unproven, and some of its impacts and economic limitations may not yet be apparent; ii) the interactions between the technology and the environment within which it will operate are not well understood in many instances, for example the impact of particulate matter on human health; and iii) the benefits arising from the removal of used batteries from the waste stream and the reduction in backyard smelting depend on responses in the informal sector and these are difficult to predict.

Despite these and other limitations the relative merits of the proposed technology are readily apparent. Assuming that the environmental and economic performances of the technology have been characterised in an accurate manner, the technology can be judged to be environmentally sound and economically viable. There is a high level of confidence that the full environmental assessment to be undertaken in response to regulatory required will confirm this finding.

Recommendations:

• a comprehensive environmental technology assessment of the proposed technology intervention should be undertaken, with special attention being given to the pressures and impacts of major concern, to reducing the uncertainties that have been identified and to only those alternative technology options that appear capable of meeting the goals of the technology intervention with comparable or lesser environmental impact;
• every reasonable effort be made to gain further information on the technical, environmental and economic performances of the proposed technology, as this is the main source of the current uncertainty;
• encourage the regulatory authority to provide greater certainty as to the environmental and other standards and agreements with which the plant will have to comply;
• encourage the development of a comprehensive national strategy on environmentally sound and economically viable management of lead, based on stakeholder involvement; and
• all stakeholders to be informed as to the findings of the current assessment, and an invitation extended to them to comment on the assessment procedures and its findings.