11-4d604f093b78e1d1.pdf

This report, prepared by GCS Water and Environment (Pty) Ltd for the Centre for Environmental Rights (CER), reviews the Integrated Water Use License Application (IWULA) and the resulting license (IWUL) issued to Atha-Africa Ventures (Pty) Ltd for the proposed Yzermyn underground coal mine in Mpumalanga. GCS concludes that the specialist studies supporting the license are fundamentally flawed, containing significant data gaps and low-confidence modeling. The review highlights a high risk of irreversible damage to sensitive wetlands and groundwater resources, noting that the IWUL lacks sufficient conditions to mitigate these impacts and fails to authorize critical post-closure water treatment needs.

• The groundwater model developed by Delta h (2014) is characterized by a low confidence level and is unsuitable for design or engineering purposes. This is due to limited monitoring data (covering only four months of a single dry season), poorly defined structural geology regarding dolerite sills and faults, and the use of a steady-state model that cannot assess seasonal variations.
• The proposed mine poses a substantial risk to high-value wetlands, specifically the NFEPA wetland CVB5, which falls within PES category B and EIS category A. GCS finds that the mine's dewatering will create cones of drawdown in both shallow and deep aquifers, potentially drying up all groundwater-dependent wetlands above the underground workings for up to 60 years.
• Specialist wetland assessments conducted by SAS (2014 and 2015) are deemed inadequate because they relied on Level 1 desktop evaluations with limited field verification and were conducted only during the dry season. Consequently, the reports failed to properly assess wetlands within the underground mining boundary or the specific impacts of the predicted groundwater drawdown.
• There is a critical lack of information regarding post-closure water management. While decant is expected approximately 45 years after operations cease, there is no detailed plan or cost analysis for a post-closure water treatment plant in the Integrated Water and Waste Management Plan (IWWMP). GCS notes that the IWUL does not authorize the necessary water use for post-closure discharge.
• The Pollution Control Dam (PCD) sizing is likely inaccurate due to the wide range of estimated mine inflow rates (218 to 3,010 m3/d) and the use of flawed rainfall data. GCS asserts that the simulated rainfall was consistently lower than measured rainfall, which may lead to the PCD being undersized and prone to spilling in an environmentally sensitive area.
• The project is located in a highly sensitive ecological area, including the Wakkerstroom/Luneburg Grasslands and adjacent to the Mabola and KwaMandlagampisi Protected Environments. The area contains several Conservation Important (CI) floral and faunal species, yet some specialist reports incorrectly claimed the habitat importance was 'extremely limited'.
• A significant portion of the coal samples (67%) were classified as potentially acid generating. GCS identifies a major gap in the assessment of pollution plumes emanating from the mine void, which could contaminate surrounding aquifers and eventually surface in rivers, wetlands, or springs.

APA

Centre for Environmental Rights (n.d.). 11-4d604f093b78e1d1.pdf. https://cer.org.za/wp-content/uploads/2020/06/11.pdf?x21779

Chicago

Centre for Environmental Rights. 11-4d604f093b78e1d1.pdf. n.d. https://cer.org.za/wp-content/uploads/2020/06/11.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=11-4d604f093b78e1d1.pdf |url=https://cer.org.za/wp-content/uploads/2020/06/11.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrightsnd114d604f093b78e1d1pdf, author = {{Centre for Environmental Rights}}, title = {{11-4d604f093b78e1d1.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2020/06/11.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }