1.4-annexures-4-29c174f5574f969f.pdf

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.

• 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.
• 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.
• 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.
• 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.
• 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.
• 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.
• 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.
• 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.

APA

Centre for Environmental Rights (n.d.). 1.4-annexures-4-29c174f5574f969f.pdf. https://cer.org.za/wp-content/uploads/2011/12/1.4-Annexures-4.pdf?x21779

Chicago

Centre for Environmental Rights. 1.4-annexures-4-29c174f5574f969f.pdf. n.d. https://cer.org.za/wp-content/uploads/2011/12/1.4-Annexures-4.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=1.4-annexures-4-29c174f5574f969f.pdf |url=https://cer.org.za/wp-content/uploads/2011/12/1.4-Annexures-4.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrightsnd14annexures429c174f5574f969fpdf, author = {{Centre for Environmental Rights}}, title = {{1.4-annexures-4-29c174f5574f969f.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2011/12/1.4-Annexures-4.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }