{"query_echo":{"q":"","filters":{"climate_tags":["acid mine drainage"]},"warnings":[{"code":"facet_value_not_in_vocabulary","message":"Value 'acid mine drainage' for facet 'climate_tags' is not in the controlled vocabulary."}]},"total":{"value":9,"relation":"eq"},"page":1,"page_size":20,"self":"https://climateinsightsdirectory.org/api/v1/search?climate_tags=acid+mine+drainage","stability":"beta","ai_marking":{"digital_source_type":{"uri":"http://cv.iptc.org/newscodes/digitalsourcetype/trainedAlgorithmicMedia","name":"Created using Generative AI"},"notice":"Summary and key insights are generated using artificial intelligence."},"results":[{"id":"cer-000591","url":"https://climateinsightsdirectory.org/document/cer-000591","title":"COMMENTS BY THE CENTRE FOR ENVIRONMENAL RIGHTS ON THE DRAFT MINE WATER MANAGEMENT POLICY POSITION","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2017-09-04","source_url":"https://cer.org.za/wp-content/uploads/2016/08/CER-comments-on-the-Draft-Mine-Water-Management-Policy-Position-4-September-2017.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The Centre for Environmental Rights (CER) provides critical feedback on the Department of Water and Sanitation's (DWS) draft Mine Water Management Policy Position. The CER argues that the draft understates the crisis of mine water management in South Africa, citing a systemic failure in mine closures and a lack of compliance monitoring and enforcement. The CER recommends that the DWS utilize existing legislative tools—specifically the National Water Act (NWA), the National Environmental Management Act (NEMA), and the Mineral and Petroleum Resources Development Act (MPRDA)—to enforce the 'polluter pays' principle and secure financial provisions for water treatment before granting licenses.","ai_generated":true,"unit":"cer-000591#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The CER asserts that the draft policy position understates the severity of mine water management issues, noting that mine closures rarely follow regulatory guidelines. They highlight a global trend where only 9% of 57 studied mines achieved closure, and argue that in South Africa, the impact of mining on water is often permanent due to treatment costs, non-compliance, or inadequate enforcement.","ai_generated":true,"unit":"cer-000591#insight-1","date_modified":"2026-08-17"},{"text":"The CER identifies a critical gap in the draft policy's scope, which focuses on water quality but ignores water quantity. They cite a 2015/16 incident where Tendele Mining (Pty) Ltd depleted an underground resource at the Somkhele Mine, leaving the local community without water, as evidence of the need for policies managing water abstraction during droughts.","ai_generated":true,"unit":"cer-000591#insight-2","date_modified":"2026-08-17"},{"text":"The CER argues that the DWS fails to implement Section 30 of the National Water Act (NWA), which allows the authority to require security from water use licence (WUL) applicants for their obligations. They state this is essential because the Department of Mineral Resources (DMR) often fails to require financial provision for water treatment costs.","ai_generated":true,"unit":"cer-000591#insight-3","date_modified":"2026-08-17"},{"text":"The CER recommends that the DWS integrate several existing laws into the policy framework to better protect water resources, including the National Environmental Management: Protected Areas Act (NEMPAA) to prohibit mining in critical water source areas, and the Spatial Planning and Land Use Management Act (SPLUMA) to avoid inappropriate development in those areas.","ai_generated":true,"unit":"cer-000591#insight-4","date_modified":"2026-08-17"},{"text":"The CER criticizes the 'Key Policy Considerations' in the draft, stating that questions regarding whether legal liabilities are being enforced are not policy questions but factual ones that have already been answered in the negative. They call for a shift toward improving compliance monitoring and enforcement (CME), including the appointment of a senior champion and the designation of Environmental Management Inspectors (EMIs) to enforce the NWA.","ai_generated":true,"unit":"cer-000591#insight-5","date_modified":"2026-08-17"},{"text":"The CER warns against the practice of selling marginal mines to smaller companies as a closure strategy, noting that the DMR and DWS often allow transfers of rights without adequate public participation or assessment of the transferee's financial capacity to handle environmental liabilities.","ai_generated":true,"unit":"cer-000591#insight-6","date_modified":"2026-08-17"},{"text":"The CER supports the creation of 'no-go' areas for mines in water source areas and sensitive ecosystems. They suggest amending the NWA to empower the Minister of Water and Sanitation to declare these areas, similar to powers existing under NEMA or the MPRDA.","ai_generated":true,"unit":"cer-000591#insight-7","date_modified":"2026-08-17"}],"climate_tags":["water security","mine water management","acid mine drainage","environmental regulation","sustainable development"],"geography_discussed":["KwaZulu-Natal"],"frame_perspective":[],"analysis_type":["policy review","legal commentary"]},{"id":"greenca-000096","url":"https://climateinsightsdirectory.org/document/greenca-000096","title":"National Strategy for Water re-use","publisher":{"name":"GreenCape","organization":"greencape"},"document_type":"report","language":"en","date_published":"2011-06","source_url":"https://greencape.co.za/assets/Sector-files/water/Reclamation-and-reuse/DWS-National-water-resources-strategy-2-annexure-D-national-strategy-for-water-re-use-2011.pdf","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The National Strategy for Water re-use, published by GreenCape in June 2011, outlines a framework for implementing water re-use projects in South Africa to address the country's water-stressed status. It defines various types of re-use, analyzes drivers such as cost and public perception, and identifies sector-specific needs in agriculture, industry, mining, and power generation. The strategy proposes a policy environment focused on clear guidelines, updated water quality standards, and the leveraging of private sector capacity to ensure sustainable water resource management.","ai_generated":true,"unit":"greenca-000096#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"South Africa is classified as water stressed by international standards, with water re-use currently accounting for approximately 14% of total water use. This includes an estimated 1,800 million m3 per annum of return flow in river systems.","ai_generated":true,"unit":"greenca-000096#insight-1","date_modified":"2026-08-17"},{"text":"The agricultural sector represents a significant opportunity for expansion in water re-use, as it accounts for about 60% of total water use in South Africa (approximately 7,680 million m3 per annum), yet only a small proportion of irrigated agriculture currently uses treated wastewater.","ai_generated":true,"unit":"greenca-000096#insight-2","date_modified":"2026-08-17"},{"text":"Water re-use in the municipal sector is divided into non-potable and potable uses. While indirect potable re-use is well established in South Africa, direct potable re-use has not been implemented, although it has been used in Windhoek, Namibia, since the 1970s.","ai_generated":true,"unit":"greenca-000096#insight-3","date_modified":"2026-08-17"},{"text":"The mining and power generation sectors heavily utilize water recycling and re-use to reduce costs and meet environmental mandates. Coal-fired power stations in South Africa typically operate as zero effluent discharge facilities, and the treatment of acid mine drainage (AMD) is highlighted as a critical area for turning negative environmental impacts into beneficial water use.","ai_generated":true,"unit":"greenca-000096#insight-4","date_modified":"2026-08-17"},{"text":"Several key drivers influence the choice of water re-use, including cost relative to other alternatives, water quality, treatment technology, environmental considerations, and social/cultural perceptions. Public taboos regarding the use of treated municipal wastewater for food crops or drinking water are noted as significant obstacles.","ai_generated":true,"unit":"greenca-000096#insight-5","date_modified":"2026-08-17"},{"text":"The strategy identifies a fragmented regulatory environment as a barrier to implementation, with controls spread across multiple acts including the National Water Act (Act 36 of 1998) and the National Environmental Management Act (Act 107 of 1998). The Department of Water Affairs aims to streamline this by developing practical guidelines and reviewing water quality standards.","ai_generated":true,"unit":"greenca-000096#insight-6","date_modified":"2026-08-17"},{"text":"Implementation capacity is viewed as a critical success factor. The strategy suggests that only entities with high technical and financial capacity—such as metropolitan municipalities, water boards, and private companies—are likely capable of implementing these projects, and recommends an industry-agreed accreditation system.","ai_generated":true,"unit":"greenca-000096#insight-7","date_modified":"2026-08-17"}],"climate_tags":["water scarcity","water reclamation","wastewater treatment","industrial water efficiency","acid mine drainage"],"geography_discussed":["Witwatersrand","Mpumalanga Highveld"],"frame_perspective":[],"analysis_type":["policy strategy","sectoral analysis","regulatory review"]},{"id":"cer-000064","url":"https://climateinsightsdirectory.org/document/cer-000064","title":"1.2-annexures-2-78fa702fbab040ea.pdf","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"report","language":"en","date_published":null,"source_url":"https://cer.org.za/wp-content/uploads/2011/12/1.2-Annexures-2.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"This document consists of a series of legal submissions, correspondence, and technical reports related to an appeal against the granting of a mining right to William Patrick Bower (Pty) Ltd (WPB) for a coal mine near Belfast, Mpumalanga. The materials include a hydrogeochemical study on acid mine drainage (AMD) and decant management, a responding statement from BirdLife South Africa (represented by the Centre for Environmental Rights), and an internal appeal from the Escarpment Environment Protection Group (EEPOG). The central disputes concern procedural unfairness in the consultation process, the inadequacy of environmental impact assessments—specifically regarding biodiversity and water quality—and the lack of a sustainable mine closure plan.","ai_generated":true,"unit":"cer-000064#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"A hydrogeochemical study by Geo Pollution Technologies (Pty) Ltd predicts that sulphate contamination from the rehabilitated pit could affect borehole BH4 within 50 years post-mining, though it is estimated to remain within domestic drinking water standards. Under a 'worst Case Scenario', borehole MH1 and a tributary to the Elandsfonteinspruit could be affected within 10 years, with the tributary possibly exceeding drinking water standards.","ai_generated":true,"unit":"cer-000064#insight-1","date_modified":"2026-08-17"},{"text":"BirdLife South Africa argues that the mining right was granted based on deficient information and that WPB introduced a new 'hydrogeochemical study' and a 'revised layout plan' (Opencast Layout 2013) after the right was granted, which were not before the decision-maker at the time of the original grant.","ai_generated":true,"unit":"cer-000064#insight-2","date_modified":"2026-08-17"},{"text":"The proposed mining area is identified as part of the Steenkampsberg Important Bird Area (IBA) and contains the Dullstroom Plateau Grasslands ecosystem, which the Mpumalanga Tourism and Parks Agency (MTPA) classifies as an endangered ecosystem.","ai_generated":true,"unit":"cer-000064#insight-3","date_modified":"2026-08-17"},{"text":"Appellants, including EEPOG, claim the consultation process was 'fatally flawed' because the scoping report and Social and Labour Plan (SLP) were not made available to interested and affected parties (IAPs) prior to submission, preventing meaningful engagement.","ai_generated":true,"unit":"cer-000064#insight-4","date_modified":"2026-08-17"},{"text":"Technical objections raised by mine engineer Mike Brett and Golder Associates highlight risks of acid mine drainage (AMD) and the lack of a detailed mining plan. Golder Associates notes the project is located at the headwaters of the Olifants and Nkomati catchments, making the water resources particularly sensitive to pollution.","ai_generated":true,"unit":"cer-000064#insight-5","date_modified":"2026-08-17"},{"text":"The Escarpment Environment Protection Group (EEPOG) asserts that the mining operation is unsustainable because it prioritizes a small coal reserve (estimated at 0.14% of South Africa's annual production) over irreplaceable biodiversity and high-potential agricultural soils.","ai_generated":true,"unit":"cer-000064#insight-6","date_modified":"2026-08-17"},{"text":"Appellants allege that the Regional Manager of the Department of Mineral Resources (DMR) showed extreme bias against objectors during a Regional Mining Development and Environmental Committee (RMDEC) meeting, reportedly stating that the government could not 'sterilise any mineral resource'.","ai_generated":true,"unit":"cer-000064#insight-7","date_modified":"2026-08-17"},{"text":"The document outlines passive treatment options for acid rock drainage, including flooding mined areas as soon as possible to bar oxygen from reacting with pyrite, and using a trench for decant treatment.","ai_generated":true,"unit":"cer-000064#insight-8","date_modified":"2026-08-17"}],"climate_tags":["energy transition","coal mining","acid mine drainage","biodiversity loss","water security"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["environmental impact assessment","legal appeal","hydrogeochemical modelling"]},{"id":"cer-000065","url":"https://climateinsightsdirectory.org/document/cer-000065","title":"1.4-annexures-4-29c174f5574f969f.pdf","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"report","language":"en","date_published":null,"source_url":"https://cer.org.za/wp-content/uploads/2011/12/1.4-Annexures-4.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"This document consists of several annexures related to two proposed coal mining projects in Mpumalanga, South Africa: the Lusthof Colliery and the WPB Colliery. The first part is a draft report from 2012 by Dr. Hugo van Zyl for Black Gold Coal Estates (BGCE) regarding the financial provisioning for a Reverse Osmosis Water Treatment Plant (WTP) at Lusthof Colliery, estimating a required provision of approximately R74.42 million to cover construction and 100 years of post-closure operation. The second part contains correspondence and reviews from 2013 to 2015 regarding the WPB Colliery, featuring objections from BirdLife South Africa and technical reviews by Golder Associates. These reviews highlight 'fatal flaws' in the WPB Colliery's water use license application, specifically the lack of adequate acid mine drainage (AMD) assessment, insufficient public participation, and flawed geochemical modelling for pollution mitigation.","ai_generated":true,"unit":"cer-000065#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"For the proposed Lusthof Colliery, a financial provision of approximately R74.42 million (in 2012 Rands) is estimated as the base case amount needed to fund the construction, operation, and re-capitalisation of a Reverse Osmosis Water Treatment Plant (WTP) for its life and 100 years post-closure.","ai_generated":true,"unit":"cer-000065#insight-1","date_modified":"2026-08-17"},{"text":"The financial model for the Lusthof WTP suggests that the most appropriate funding mechanism is a combination of a trust fund and a bank guarantee to ensure funds are ring-fenced against insolvency or premature closure.","ai_generated":true,"unit":"cer-000065#insight-2","date_modified":"2026-08-17"},{"text":"The Lusthof WTP financial provision is sensitive to the discount rate; a 2.5% rate increases the required provision to approximately R93.79 million, while a 4.75% rate decreases it to approximately R51.47 million.","ai_generated":true,"unit":"cer-000065#insight-3","date_modified":"2026-08-17"},{"text":"Golder Associates identified significant deficiencies in the WPB Colliery's water use license application, noting a lack of substantial documentation to assess the risk of acid mine drainage (AMD) and the absence of water management risks for post-mining water decant.","ai_generated":true,"unit":"cer-000065#insight-4","date_modified":"2026-08-17"},{"text":"BirdLife South Africa objects to the WPB Colliery's water use license on the grounds that the project is located in a sensitive environment, specifically the Steenkampsberg Important Bird Area, and would impact irreplaceable wetland systems.","ai_generated":true,"unit":"cer-000065#insight-5","date_modified":"2026-08-17"},{"text":"The WPB Colliery's water use license application is alleged to have 'fatal flaws', including the failure to apply for authorisation for discharging waste into water resources under section 21(f) of the National Water Act and a lack of proper public participation.","ai_generated":true,"unit":"cer-000065#insight-6","date_modified":"2026-08-17"},{"text":"A 2014 review by Golder Associates argues that the WPB Colliery's pollution source characterisation is deficient because it relied on a single sample of overburden material, rendering the geochemical modelling and the design of the proposed limestone barrier/buffer unreliable.","ai_generated":true,"unit":"cer-000065#insight-7","date_modified":"2026-08-17"},{"text":"The WPB Colliery's Environmental Report admits that AMD is likely to occur and that the impact on groundwater quantity and quality is of 'major importance' and 'significant', even with mitigation measures.","ai_generated":true,"unit":"cer-000065#insight-8","date_modified":"2026-08-17"}],"climate_tags":["energy transition","mining","water management","acid mine drainage","biodiversity loss"],"geography_discussed":["Belfast","Dullstroom","Steenkampsberg"],"frame_perspective":[],"analysis_type":["financial modelling","environmental impact review","legal objection"]},{"id":"cer-000112","url":"https://climateinsightsdirectory.org/document/cer-000112","title":"2011-cope-koornhof-q737-contamination-of-the-vaal-rivers-upper-catchment-from-coal-mining-and-abandoned-mines-causing-acid-mine-drainage-35cd3757c18b62f2.pdf","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"briefing","language":"en","date_published":null,"source_url":"https://cer.org.za/wp-content/uploads/2011/11/2011-COPE-Koornhof-Q737-Contamination-of-the-Vaal-Rivers-upper-catchment-from-coal-mining-and-abandoned-mines-causing-acid-mine-drainage.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"This document is a draft written reply from the South African Minister of Water and Environmental Affairs to a National Assembly question (Question 737) posed by Mr N J J van R Koornhof of the COPE party in March 2011. The inquiry focuses on the contamination of the Vaal River's upper catchment due to coal mining and the risk of acid mine drainage from abandoned mines.","ai_generated":true,"unit":"cer-000112#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The Department of Water and Environmental Affairs acknowledges that the upper catchment of the Vaal River contains substantial underlying coal reserves, and as a result, the Department carefully considers all applications for water use authorisations submitted by mining companies.","ai_generated":true,"unit":"cer-000112#insight-1","date_modified":"2026-08-17"},{"text":"A strategy to rehabilitate abandoned mines to prevent acid mine drainage is currently being developed by the Department of Mineral Resources (DMR), with the Department of Water and Environmental Affairs providing inputs toward its development.","ai_generated":true,"unit":"cer-000112#insight-2","date_modified":"2026-08-17"},{"text":"To minimize the risk of water source contamination, the Department of Water and Environmental Affairs provides inputs on environmental management plans for mines through cooperative governance.","ai_generated":true,"unit":"cer-000112#insight-3","date_modified":"2026-08-17"}],"climate_tags":["water resources","mining","acid mine drainage","environmental management"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["policy response"]},{"id":"cer-000113","url":"https://climateinsightsdirectory.org/document/cer-000113","title":"2011-cope-ndude-q2976-departmental-directive-and-compliance-pertaining-to-acid-mine-drainage-1e8333a621d7fcf0.pdf","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"briefing","language":"en","date_published":null,"source_url":"https://cer.org.za/wp-content/uploads/2011/11/2011-COPE-Ndude-Q2976-Departmental-directive-and-compliance-pertaining-to-acid-mine-drainage.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"This document is a draft written reply from the South African Minister of Water and Environmental Affairs to a National Assembly question (No. 2976) asked by Mrs H N Ndude regarding departmental directives and compliance for mines concerning acid mine drainage (AMD).","ai_generated":true,"unit":"cer-000113#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"Since May 2010, the Department of Water and Environmental Affairs has not issued any directives to Witwatersrand mines regarding Acid Mine Drainage (AMD), opting instead to work with existing mines on short-term interventions such as utilizing existing mine water treatment plants.","ai_generated":true,"unit":"cer-000113#insight-1","date_modified":"2026-08-17"},{"text":"The Department intends to use sections 19 and 20 notices of the National Water Act, 1998 (Act 36 of 1998) to direct both defunct and existing Witwatersrand mines to participate in AMD management solutions. Depending on investigation outcomes, these directives may require mines to contribute to the costs of implementing short-term solutions, with the Trans-Caledon Tunnel Authority serving as the implementing agent.","ai_generated":true,"unit":"cer-000113#insight-2","date_modified":"2026-08-17"}],"climate_tags":["acid mine drainage","water management","mining regulation"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["policy response"]},{"id":"cer-000140","url":"https://climateinsightsdirectory.org/document/cer-000140","title":"2011-da-morgan-q1816-current-location-of-all-decant-points-of-acid-mine-drainage-on-the-west-rand-and-related-ph-and-sulphate-levels-b18af813b208d5d3.pdf","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"briefing","language":"en","date_published":null,"source_url":"https://cer.org.za/wp-content/uploads/2011/11/2011-DA-Morgan-Q1816-Current-location-of-all-decant-points-of-acid-mine-drainage-on-the-West-Rand-and-related-pH-and-sulphate-levels.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"This document is a draft written reply from the South African Minister of Water and Environmental Affairs to a National Assembly question (Question 1816) asked by Mr G R Morgan (DA) regarding acid mine drainage (AMD) on the West Rand.","ai_generated":true,"unit":"cer-000140#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"Acid mine drainage (AMD) decant on the West Rand occurs primarily from the Black Reef Incline (BRI) adit and abandoned mine shafts 17 Winze and 18 Winze, with additional nominal seepage from other spots on the Rand Uranium Pty Ltd property. All this water is diverted into the BRI dam, which is a lined mine water pollution control dam.","ai_generated":true,"unit":"cer-000140#insight-1","date_modified":"2026-08-17"},{"text":"During the initial decant on the Rand Uranium Pty Ltd property in 2002, the pH started around neutral (pH 7) before decreasing to pH 3.7, and the sulphate level was approximately 5000 mg/L.","ai_generated":true,"unit":"cer-000140#insight-2","date_modified":"2026-08-17"},{"text":"As of May 2011, untreated decanting AMD measured at the BRI dam had a pH of 5.2 and a sulphate level of 3700 mg/L.","ai_generated":true,"unit":"cer-000140#insight-3","date_modified":"2026-08-17"},{"text":"The increase in pH (becoming less acidic) is attributed to the use of strongly alkaline water during the deposition of mine tailings into the nearby West Wits Pit. The decrease in sulphate levels is attributed to a dilution effect from recent high rainfall and potential reactions with sulphate during tailings deposition in the West Wits Pit that form insoluble solids.","ai_generated":true,"unit":"cer-000140#insight-4","date_modified":"2026-08-17"}],"climate_tags":["acid mine drainage","water pollution","mining"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["water quality monitoring"]},{"id":"cer-000141","url":"https://climateinsightsdirectory.org/document/cer-000141","title":"2011-da-morgan-q223-status-of-acid-mine-drainage-in-the-western-central-and-eastern-basins-94d80b7743e9e039.pdf","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"briefing","language":"en","date_published":null,"source_url":"https://cer.org.za/wp-content/uploads/2011/11/2011-DA-Morgan-Q223-Status-of-acid-mine-drainage-in-the-western-central-and-eastern-basins.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags"],"summary":{"text":"A draft reply from the South African Minister of Water and Environmental Affairs to a National Assembly question regarding the status of acid mine drainage responses in the western, central, and eastern basins.","ai_generated":true,"unit":"cer-000141#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The Department has approved an emergency solution for the Western Basin involving the upgrade of an existing mine water treatment facility to treat between 27 and 32 million litres of mine water daily, with a short-term solution to run in parallel to treat all decanting water.","ai_generated":true,"unit":"cer-000141#insight-1","date_modified":"2026-08-17"},{"text":"Short-term solutions for the Central and Eastern Basins focus on neutralising mine water to prevent underground water levels from reaching their respective Environmental Critical Levels (ECL), which are set at 186 metres below the surface for the Central Basin and 290 metres below the surface for the Eastern Basin.","ai_generated":true,"unit":"cer-000141#insight-2","date_modified":"2026-08-17"},{"text":"The proposed short-term solutions across all basins involve installing pumps to extract underground water and using neutralisation processes in treatment plants to remove heavy metals and adjust pH levels. Commissioning dates are projected for February 2012 (immediate) and August 2012 (short-term) for the Western Basin, August 2012 for the Central Basin, and February 2013 for the Eastern Basin.","ai_generated":true,"unit":"cer-000141#insight-3","date_modified":"2026-08-17"}],"climate_tags":["acid mine drainage","water treatment","environmental critical level"],"geography_discussed":[],"frame_perspective":[],"analysis_type":[]},{"id":"cer-000513","url":"https://climateinsightsdirectory.org/document/cer-000513","title":"APPELLANTS’ HEADS OF ARGUMENT IN THE APPEAL IN TERMS OF SECTION 149 OF THE NATIONAL WATER ACT NO. 36 OF 1998","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"report","language":"en","date_published":null,"source_url":"https://cer.org.za/wp-content/uploads/2021/03/Appellants-heads-of-argument.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"This document contains the Appellants' Heads of Argument filed by the Centre for Environmental Rights on behalf of the Endangered Wildlife Trust and the Federation for a Sustainable Environment. The appeal, brought under section 149 of the National Water Act (NWA), challenges a Water Tribunal decision that dismissed an appeal against the granting of a water use licence (WUL) to Atha-Africa Ventures (Pty) Ltd for the proposed Yzermyn Underground Coal Mine. The appellants argue that the Water Tribunal erred on several questions of law, including the failure to consider the strategic importance of the mine area, the absence of landowner consent, the misapplication of the precautionary principle, the lack of post-closure water treatment provisions, and the misapprehension of the burden of proof regarding socio-economic impacts.","ai_generated":true,"unit":"cer-000513#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The proposed Yzermyn Underground Coal Mine is located in an area of high environmental sensitivity, identified as a Strategic Water Source Area (SWSA), part of a protected environment under the National Environmental Management: Protected Areas Act, and an endangered ecosystem under the Biodiversity Act.","ai_generated":true,"unit":"cer-000513#insight-1","date_modified":"2026-08-17"},{"text":"The mine is expected to cause three primary water impacts: 'dewatering' of aquifers which affects springs and wetlands, the 'decant' of contaminated water (including acid mine drainage) post-closure, and the accumulation of toxic water in groundwater plumes before decant occurs.","ai_generated":true,"unit":"cer-000513#insight-2","date_modified":"2026-08-17"},{"text":"The appellants argue the Water Tribunal erred by dismissing evidence of the mine area's strategic importance as irrelevant, claiming the Tribunal wrongly held that national-level studies (like SWSA reports) are not applicable to project-level decisions.","ai_generated":true,"unit":"cer-000513#insight-3","date_modified":"2026-08-17"},{"text":"The appellants contend that the WUL was granted in violation of section 24 of the NWA because the owner of the farm Zoetfontein 94 HT did not consent to the use of underground water, and no 'good public reason' was provided to override this requirement.","ai_generated":true,"unit":"cer-000513#insight-4","date_modified":"2026-08-17"},{"text":"The appellants claim the Water Tribunal failed to apply the precautionary principle from NEMA, which requires a risk-averse approach when scientific knowledge is limited. They cite 'low confidence' in the groundwater assessments and uncertainty regarding the adequacy of mitigation for acid mine drainage.","ai_generated":true,"unit":"cer-000513#insight-5","date_modified":"2026-08-17"},{"text":"The WUL is criticized for failing to provide for the post-closure treatment of contaminated water, as it is only valid for the 15-year life of the mine and lacks financial security for long-term water treatment.","ai_generated":true,"unit":"cer-000513#insight-6","date_modified":"2026-08-17"},{"text":"The appellants argue the Water Tribunal wrongly shifted the burden of proof regarding socio-economic impacts onto the appellants, whereas the statutory duty of justification lies with the licence applicant (Atha).","ai_generated":true,"unit":"cer-000513#insight-7","date_modified":"2026-08-17"}],"climate_tags":["water security","acid mine drainage","groundwater contamination","biodiversity loss","sustainable development","precautionary principle"],"geography_discussed":["Mpumalanga","Assegaai River","Mabola Protected Environment"],"frame_perspective":[],"analysis_type":["legal_argument","environmental_impact_review"]}]}