IWULA, IWUL and Specialist Investigation Review of the Yzermyn Colliery Mpumalanga

This report, prepared by GCS Water and Environment (Pty) Ltd for the Centre for Environmental Rights, reviews the Integrated Water Use License Application (IWULA) and the resulting Integrated Water Use License (IWUL) issued to Atha-Africa Ventures (Pty) Ltd for the proposed Yzermyn underground coal mine in Mpumalanga. The review identifies significant gaps in the specialist studies regarding hydrogeology, wetlands, and hydrology, concluding that the IWUL was issued without a full understanding of the environmental impacts and the interconnection between water resources.

• The groundwater model developed by Delta h (2014) is considered to have low confidence (Class 1) because it was run in steady-state and lacks seasonal groundwater elevation and spring discharge data. This makes it unsuitable for design, engineering, or assessing seasonal variations in groundwater levels and their impacts on springs and wetlands.
• There is a critical lack of site-specific hydrogeological data regarding dolerite sills, dykes, and faults, which are known to significantly influence groundwater flow. The absence of this information means the potential environmental impacts and the effectiveness of mitigation measures may be mischaracterized.
• The mine is located in a threatened ecosystem (Wakkerstroom/Luneburg Grassland) and near protected environments, including the Mabola and KwaMandlagampisi Protected Environments. GCS concludes that underground mining will cause a drawdown of 2m to 5m in the shallow aquifer, which will negatively impact groundwater-dependent ecosystems and cause some springs and wetlands to dry up.
• Wetland assessments were inadequate because they relied on desktop delineations for the underground mining area rather than field ground-truthing. Additionally, there are contradictions between different reports; some describe the wetlands as 'largely natural' (Category A/B) while others describe them as 'highly disturbed' with 'limited Ecological Importance and Sensitivity'.
• The hydrological assessments are based on outdated mine layouts and fail to account for the updated groundwater model. Specifically, the Pollution Control Dams (PCDs) are incorrectly sized because they were not designed to be operated nearly empty, increasing the risk of spills in an environmentally sensitive area.
• The reports fail to adequately address post-closure risks, specifically the migration of contaminant plumes from mine workings and shafts. While mine water decant is expected, the predicted water quality was based on data from the Hlobane mine 82km away rather than site-specific assessments.
• The Integrated Water Use License (IWUL) issued on 7 July 2016 is deemed insufficient because it is based on specialist reports that did not identify all potential impacts. Consequently, the license lacks the necessary conditions to ensure that environmental impacts can be mitigated to an acceptable standard.
• The application for exemptions from General Notice 704 (GN 704) was based on unassessed mitigation measures, such as grouting and discharging treated water into wetlands, for which there is no established scientific basis for effectiveness.

APA

Koning, A., Bredenkamp, B., King, K., & Langlands, K. (2016). IWULA, IWUL and Specialist Investigation Review of the Yzermyn Colliery Mpumalanga. Centre for Environmental Rights. https://cer.org.za/wp-content/uploads/2011/12/Annexure-G.pdf?x21779

Chicago

Koning, Alvar, Brendon Bredenkamp, Karen King, and Kate Langlands. IWULA, IWUL and Specialist Investigation Review of the Yzermyn Colliery Mpumalanga. Centre for Environmental Rights, 2016. https://cer.org.za/wp-content/uploads/2011/12/Annexure-G.pdf?x21779.

Wikipedia

{{cite report |last1=Koning |first1=Alvar |last2=Bredenkamp |first2=Brendon |last3=King |first3=Karen |last4=Langlands |first4=Kate |title=IWULA, IWUL and Specialist Investigation Review of the Yzermyn Colliery Mpumalanga |publisher=Centre for Environmental Rights |date=18 November 2016 |url=https://cer.org.za/wp-content/uploads/2011/12/Annexure-G.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{koning2016iwula, author = {Koning, Alvar and Bredenkamp, Brendon and King, Karen and Langlands, Kate}, title = {{IWULA, IWUL and Specialist Investigation Review of the Yzermyn Colliery Mpumalanga}}, institution = {Centre for Environmental Rights}, year = {2016}, month = nov, url = {https://cer.org.za/wp-content/uploads/2011/12/Annexure-G.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }