1.2-annexures-2-78fa702fbab040ea.pdf

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.

• 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.
• 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.
• 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.
• 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.
• 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.
• 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.
• 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'.
• 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.

APA

Centre for Environmental Rights (n.d.). 1.2-annexures-2-78fa702fbab040ea.pdf. https://cer.org.za/wp-content/uploads/2011/12/1.2-Annexures-2.pdf?x21779

Chicago

Centre for Environmental Rights. 1.2-annexures-2-78fa702fbab040ea.pdf. n.d. https://cer.org.za/wp-content/uploads/2011/12/1.2-Annexures-2.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=1.2-annexures-2-78fa702fbab040ea.pdf |url=https://cer.org.za/wp-content/uploads/2011/12/1.2-Annexures-2.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrightsnd12annexures278fa702fbab040eapdf, author = {{Centre for Environmental Rights}}, title = {{1.2-annexures-2-78fa702fbab040ea.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2011/12/1.2-Annexures-2.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }