IWULA, IWUL and Specialist Review

The review finds that the IWUL was issued based on inadequate specialist studies that failed to identify all potential impacts, particularly regarding groundwater-wetland interlinkages and post-closure mine water decant. It argues that the license conditions are too general and fail to incorporate specific mitigation measures. Additionally, the document assesses the socio-economic landscape of the project area, highlighting the vulnerability of farm tenants and the need for comprehensive skills development and resettlement plans to mitigate negative social impacts.

• The Department of Water and Sanitation (DWS) issued the IWUL without sufficient information to make a sound decision because specialist reports failed to identify all impacts associated with the planned mine.
• The IWUL lacks express mitigation measures and instead incorporates specialist reports by reference, some of which are described as nonsensical, such as requiring that no decant occurs post-closure without providing a pumping mitigation measure.
• Groundwater and wetland assessments were inadequate, relying on desktop studies rather than field delineation, and failed to account for the impact of a 5m drawdown on wetlands above the underground mining area.
• Hydrological assessments are based on outdated information and fail to account for Acid Mine Drainage (AMD), which would alter water quality-related risks and mitigation measures.
• The proposed mine is located within a threatened ecosystem, and the review concludes that no assessed mitigation measures are likely to prevent this impact.
• The project poses an unacceptable risk to a specific homestead located approximately 500m from the proposed adit entrance due to potential vibrations, dust, and noise, necessitating a Resettlement Plan.
• Local communities, particularly farm tenants, are highly vulnerable with low education levels and limited income, averaging R2 200 per month per household.
• The Social and Labour Plan (SLP) identifies a significant skills gap in the local area, requiring Atha to implement Adult Basic Education and Training (ABET) and portable skills training to ensure local employment.

APA

Centre for Environmental Rights (2017). IWULA, IWUL and Specialist Review. https://cer.org.za/wp-content/uploads/2020/06/12.pdf?x21779

Chicago

Centre for Environmental Rights. IWULA, IWUL and Specialist Review. 2017. https://cer.org.za/wp-content/uploads/2020/06/12.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=IWULA, IWUL and Specialist Review |date=1 December 2017 |url=https://cer.org.za/wp-content/uploads/2020/06/12.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrights2017iwula, author = {{Centre for Environmental Rights}}, title = {{IWULA, IWUL and Specialist Review}}, institution = {Centre for Environmental Rights}, year = {2017}, month = dec, url = {https://cer.org.za/wp-content/uploads/2020/06/12.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }