Formal provisions for SEA can be made under EIA or other legislation, or separate administrative orders or policy guidelines. Generally, SEA systems that apply to plans and programmes are based or modelled on EIA legislation, and follow the same or comparable requirements and procedures [11] . This is the case for Kenya and Tanzania where formal provisions for SEA are included in the Environmental (Impact Assessment and Audit) Regulations [12] and in the Environmental Management Act [13] , respectively. SEA is performed for the three tiers of strategic decisions, namely policies, plans and programmes.

South Africa uses SEA on an ad hoc basis to assist in policy formulation [11] . South Africa has a voluntary SEA system and thus does not implement SEA according to a legally-prescribed process. Nevertheless, several policy initiatives address the need for SEA, including the White Paper on Environmental Management Policy for South Africa [14] and a discussion document entitled “A National Strategy for Integrated Environmental Management (IEM) in South Africa” [15] . The National Environmental Management Act No 107 of 1998 (Republic of South Africa) [16] as amended⁵ includes provisions for assessment procedures to ensure that the environmental consequences of policies, plans and programmes are considered. In addition, South Africa has two SEA guidance documents: the Strategic Environmental Assessment in South Africa―Guideline Document [17] , which sets out, inter alia, best practices and a generic approach to SEA, and the Strategic Environmental Assessment Guidelines, Integrated Environmental Guideline Series 4 [18] , which provides detailed guidance on key elements of the SEA process, rather than a prescriptive step-by-step process. SEA is used at the three levels of strategic decision-making.

Screening is undertaken to determine the potential of a policy, plan or programme to significantly impact the environment and thus to decide whether or not a SEA is required. While screening methods and techniques will vary according to the nature and the objectives of the proposal and the decision-makers’ need, the SEA process must remain focused on key strategic issues and take into account capacity constraints. The practice exists in all three countries, however, only South Africa screens using a positive list.

Scoping determines the nature and extent of the SEA, identifying the key environmental issues and alternatives at a strategic level that which should be investigated in more detail. Stakeholder engagement, including specialists and authorities, is a key technique for identifying strategic issues [17] . In Kenya and Tanzania, the Environmental (Impact Assessment and Audit) Regulations and the Environmental Management Act [12] [13] , respectively, do not include requirements regard scoping. However, from the literature review, we have determined that the practice exists. In South Africa, the two SEA Guidance documents provide a detailed description of scoping process [17] [18] .

Public involvement in the SEA process ranges from merely being informed on the SEA process, to providing inputs or being actively involved in influencing the process. The public participation process should be designed in such a way that it enhances the entire SEA process [17] . All three countries have introduced some form of public participation in their SEA process.

All three countries require the consideration of alternatives to the proposed policy, plan or programme. However, even in the case of South Africa, few details on the type or hierarchy of alternatives (need/demand, mode/ process, location, and timing/implementation) or minimum requirements regarding scenario identification are provided. Likewise, each of the countries has stipulated requirements for indicating measures to reduce or mitigate the potential significant effects on the environment of the proposed strategic action, with those from South Africa being the more detailed.

Finally, SEA review is practised in both Tanzania and South Africa. The review evaluates the positive and negative aspects of the framework for sustainability and the final draft of the plan or programme. The review step is a means to monitor the quality of the presented information, which is the basis for decision-making, and thereby pre-determines the suitability, practical feasibility, and sustainability of the resulting strategic action.

A clear mandate and institutional framework setting out the lead institution is vital to the SEA process. The in- stitutional framework will pre-determine the leverage points for SEA inputs in the planning and decision-mak- ing process, the focus of SEA, coordination and consultation opportunities, facilite public and stakeholder par- ticipation, and provide a map of procedural arrangements. Figures 2-4 set out the institutional framework in Kenya, Tanzania and South Africa respectively.

In each country, the SEA is initiated by the proponent authority. In Kenya, the party responsible for conducting SEA is also the proponent authority (the ministry responsible for the PPPs); in South Africa, it is a pre- qualified environmental assessment practitioner. In Tanzania the SEA is conducted on the basis of the nature of the project under consideration. In cases involving mineral or petroleum resources, hydro-electric power stations, or major water projects, the ministry responsible for mining, energy or water carries out the SEA. For all other cases, the SEA is carried out by the ministry responsible for matters relating to the environment.

South Africa and Tanzania require a review of SEA findings. In Tanzania, the Director of Environment reviews the SEA statement and submits a review report to the minister responsible for matters relating to the environment. In South Africa, according to the two Guidance documents [17] [18] , the review is required, although responsibilities are not assigned to specific government authorities to perform the review. The review process can include relevant authorities, specialists, and interested and affected parties.

Forests in Kenya are an important source of livelihood, environmental services, and economic growth. Traditionally, the government assumed full management responsibility for gazetted forest reserves [19] . In November of 2005, the Government of Kenya ratified a new Forests Act that emphasizes partnerships with community associations, the engagement of local communities, and promotion of private investment. An institution-centred SEA (I- SEA ) was undertaken to inform and influence the process of implementing the new Act, to indirectly facilitate policy dialogue regarding sustainable use of natural resources for national development, and to draw lessons to refine future I-SEAs. It followed international good practice and the four-phase approach for I-SEAs supported by the World Bank: screening and scoping; situation assessments; setting environmental priorities; and development of alternative courses of action (Figure 5).

A noteworthy element of this I-SEA was its reliance on the active participation of a wide range of stakeholders, including community associations, through workshops and one-on-one discussions. This dialogue was essential in identifying key issues and priorities for action. In addition, the I-SEA acknowledged the adverse effects that shortcomings in existing legislation, and the institutional and governance weaknesses of previous ad-

ministrations have had on forest environments. Looking holistically at environmental, social and economic considerations, the I-SEA set out an informed and realistic policy action matrix. This matrix captured findings and recommendations and established clear timetables and responsibilities for action.

A report by the Government of Kenya [20] identified several lessons learned:

・ The majority of stakeholders were unfamiliar with the concept of SEA, or its potential value to the reform process. This raises two important issues in planning future I-SEAs: What skills are needed for SEA?; and What level of support is needed in briefing and training stakeholders in their SEA role?

・ The initial stages of setting up an I-SEA are critical, as is ensuring that relevant government ministries and agencies have endorsed and understand the process before work begins.

・ Participation of at least one government official on the SEA consultancy team is necessary to strengthen ownership and continuity of the process and its implementation, to obtain the commitment of the relevant government departments, to facilitate access to government expertise, and to build long-term capacity for SEA. Stakeholder engagement and ownership of the process is essential to the success of a SEA.

Dar es Salaam obtains most of its water from two offtakes on the Ruvu River, as well as the Mtoni River, and

shallow aquifers. Continued population growth has made its water supply precarious, especially during the dry season when river levels fall. A long-term water supply master plan was drawn up [21] following a review of 26 surface and ground water, inter-basin transfer, and desalination options. The SEA ranked the 26 options in terms of their technical soundness, economics, and impacts and mitigation costs. The SEA was tiered to an EIA of each option by proposing the key social and environmental factors, as well as sensitive issues requiring special attention, to be addressed by an EIA; a preliminary strategy and work plan for undertaking an EIA; and the use of an international panel of experts to guide the EIA process. Although the SEA has narrowed the number of potential water sources to two, its influence on the choice of water supply is yet to be seen. However, this SEA illustrates the value of early integration of environmental and social criteria in the decision-making process and assessment of a wide range of options in a transparent manner.

This SEA was carried out to understand the likely environmental and social impacts of the tourist sector development plans in the Northern Circuit of Tanzania against sustainability objectives. Economic valuation of the potential sites and current tourist attractions was undertaken to assess the economic benefit of conserving these sites [22] . The economic valuation process demonstrated the considerable economic benefits accruing to the area, as well as the significant negative environmental impacts of the activities individually and cumulatively. The SEA also revealed the problem of enforceability of already existing guidelines on good practices for sustainable tourism development in the region.

Lake Victoria, by area the second largest freshwater lake in the world, is experiencing social and environmental stresses including widespread watershed degradation, increasing water pollution, rising prevalence of water borne diseases, increasing conflicts over access to and use of natural resources, declining fisheries, loss of aquatic and terrestrial biodiversity, and more frequent and more severe droughts and floods. More recently, the rapidly declining lake levels as a result of hydropower generation have created serious social, ecological, and economic problems and political tension in the region [23] .

Numerous international donors have stepped in to provide assistance to the riparian and basin governments address these issues. The largest and most complex of these projects was the World Bank managed Lake Victoria Environmental Management Project (LVEMP) towards which the Global Environment Facility (GEF) contributed [24] . The GEF/IDA funded project ran from 1996 to 2002 (Tanzania) and 2005 (Uganda and Kenya). This SEA represents the only transboundary process reviewed in this analysis and offers special insights into the SEA process in transboundary situations.

Although a mutually-agreed vision statement laid the basis for cooperative management of the lake basin, it fell short of providing a prioritized list of issues to be tackled through a coordinated programme of action by the basin countries. Consequently, GEF funded the Lake Victoria Development Program to produce a regional Transboundary Diagnostic Analysis and Strategic Action Program (TDA/SAP) between 2004 and 2007 as a foundation for the formulation of the second phase of the LVEMP.

A two-step process was used to develop the TDA/SAP. In the first stage, national TDAs were produced identifying the major priority transboundary issues using various tools and information sources in each country and these were ranked on the basis of each country’s perception. In the second stage, these national priorities were reviewed regionally on the basis of the spatial extent of both environmental and socioeconomic impacts. Their root and immediate causes were investigated through causal-chain analysis, which included identification of institutional, legal, and policy issues that impeded their management. The regional SAP drew upon further stakeholder consultations, the national and regional TDAs and other material to identify a series of key transboundary issues.

Several lessons can be learned from this complex SEA process [23] :

・ Complex transboundary projects such as this require that comparable methods, targets, and indicators are used in each country to identify and rank issues. Where there is great disparity in the size of the countries and the importance of the resource or ecosystem to each country’s economy and social life (as was the case here), greater emphasis may need to be placed on some country’s perceptions than others. Collation of national priorities into a regional priority provides an opportunity to correct some inconsistencies and omissions between the national priority setting exercises (e.g., TDAs), but that opportunity may not always be available.

・ In this case study, the SEA was an externally required condition, which is not necessarily a strong foundation for ensuring implementation of the SEA recommendations. In this case, however, widespread government, professional and public support for sustainable development within the basin, through both multilateral and bilateral projects and the SEA process itself, provided an opportunity to structure common issues and responses.

・ The two outputs from this project―the regional TDA and SAP―are overlapping and confusing. They use different terminology, structure priorities in different ways, and appear to be in competition in their attempts to identify priority issues.

・ Although the level of stakeholder participation across the national TDAs, regional TDA, and SAP processes was commendable, it can skew the choice of issues and override the results of more analytical work. Both scientifically-based analytical information and stakeholder understanding and objectives need to be balanced in order to achieve a well-founded SEA process. The procedures used in transboundary SEAs must be carefully considered and agreed on to ensure that the recommendations represent the true importance of the issue to each country, e.g., in this case, the decline in lake level, which is of great economic and social importance to large population countries, was down-weighted in the regional TDA and SAP as equal weight was given to each national TDA and SAP.

Prior to 1994, SEA related to water resource management in South Africa focussed on conflicts arising from permitting for afforestation. A comprehensive consultation exercise initiated by the national Department of Water Affairs and Forestry (DWAF) indicated the need for a more holistic approach to permitting that extended the focus of SEA beyond forestry [25] . In 2000-2004, the DWAF, undertook a water use SEA that considered the biophysical, social, and economic impacts of the use and allocation of water in the Mhlathuze Catchment in KwaZulu Natal. The study initially focused on licensing water use for new forestation, but its coverage was expanded to include all water uses in the catchment, including the implementation of the concepts of the human and ecological water reserves [26] [27] .

This study is an example of an impact-centred SEA, undertaken to obtain information for a subsequent plan. This SEA was intended to inform all levels of decision-making from project to policy level. However, the SEA lacked focus in key areas of the SEA process, e.g., data collection for the GIS and scoping objectives. The absence of institutional structures (i.e., a clear focus in the decision-making process) meant that it was unable to be tiered to project or plan levels, although it did enhance support for integrated water resources management at the programme level within DWAF, although not for the added value that SEA would bring to that programme [23] .

A formal public participation process was conducted as part of the social analysis component and was considered a cornerstone of the SEA. Focused on communal rural areas because they represented the largest and neediest group, the participation process also included a stakeholder workshop attended by representatives of agriculture and industry. Attendance numbers suggests that the process was well received, although the non- alignment of catchment boundaries with institutional boundaries left pockets of the catchment area unrepresented. This case study demonstrates the importance of scale in the SEA process. The heterogeneity of the water management area mitigated against a single SEA study because each community had diverse water use objectives.

Overall, the lack of a clear objective, a focused client, and a well-designed work plan meant that this SEA did not lead to direct outcomes and that the initiative withered within the sponsoring government department.

From humble beginnings in 1931 to protect the dwindling population of Eastern Cape elephants, South Africa announced ambitious plans for the Addo Elephant National Park (AENP) to integrate and extend existing conservation areas in the region. The new enlarged park would be the third largest national park in South Africa and cover six of the seven South African biomes, a potentially significant contribution to biodiversity conservation in Africa (adapted from CES [28] and Retief [25] ). This SEA considered one overriding land use option, namely conservation, together with various options for boundaries and institutional and management strategies.

The goals of the SEA for the greater AENP were to synthesise existing socio-economic and biophysical information, determine environmental opportunities and constraints presented by proposed expansion, recommend ways to optimize opportunities and minimise constraints, and to distribute this information to interested and affected parties, while at the same time highlighting World Bank Safeguard Policies. To ensure transparency in the planning process, the SEA encouraged stakeholders and other interested and affected parties to become involved in the process at an early stage.

Several lessons can be learned from this SEA:

・ If a SEA is not integrated into the conceptualisation phase of a project or programme, it will be difficult for the SEA to purposefully influence important decisions concerning the vision and strategic objectives of that project or programme. Implementation of the SEA recommendations will also be determined by the SEA mandate and legal framework. Ideally, a SEA should be conducted within a clearly defined regulatory and institutional framework to ensure that outcomes are considered and incorporated into decision-making.

・ A balance needs to be struck between conservation targets and socio-economic development priorities.

・ Setting and communicating spatial boundaries must be stated clearly up front and communicated to those affected to avoid mistrust within the affected communities, which ultimately hampers buy-in to the project or programme.

・ It is extremely difficult to consider trade-offs between bio-physical and social impacts if the scale and level of detail of the data differs. In the design of the SEA methodology, special consideration must be given to alignment of the different specialist studies to facilitate data integration.

Collectively, these cases illustrate a range of SEA experiences and models across the three African Countries and under a variety of assessment systems and planning frameworks. Table 1 evaluates each case study against the system, process, and results performance criteria applied in this research (see Methodology above).

The case studies reveal that the major limitation in all the SEA processes examined here was the lack of a tiered system of assessment and decision-making that carries SEA results on to the next step. Only two cases provided for some form of tiering mechanism. If SEA recommendations are to be influential, SEA results must inform decisions inputs to the next tier, and SEA objectives must be informed by the decision outputs of previous tiers of assessment and decision-making. Only one of the case studies actually identified a ‘best’ option or strategic direction. An additional five cases partially met this criterion. In six case studies there was a clear delineation of assessment roles and responsibilities, but only one case partially met the criterion mechanisms to ensure impartiality/ independence of assessment review.

The consideration and assessment of a reasonable range of alternatives or scenarios, is a defining characteristic of SEA. This was clearly evident in the SEA of the Future Dar es Salaam Water Supply Options; in contrast, the Lake Victoria SEA did not provide any sort of comparative evaluation of alternatives and scenarios. The other cases demonstrated only a limited consideration of assessment alternatives. So, the potential for alternatives consideration is not equal under every SEA system or application. Additionally, although all three countries require the evaluation of environmental impacts, only the Dar es Salaam SEA identified the potential impacts or outcomes from each option or scenario under consideration. Five other cases met this criterion to some extent.

Finally, three case studies clearly demonstrated a formal, required programme for follow-up and monitoring of outcomes and decisions for corrective actions. All these three cases, interestingly, met the sustainable development criteria, and two of them met the participation and transparency criteria as well.