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Review of the Yzermyn Financial Provision for the Centre for Environmental Rights Report

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GCS Water and Environment reviewed the financial provisioning for the Yzermyn coal mine and found it insufficient. The report highlights the omission of costs for wetland rehabilitation, offsets, and long-term wastewater treatment for mine decant. It provides revised cost estimates, arguing that significant residual environmental impacts require substantial additional funding for offsets and long-term management to meet regulatory requirements.

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  • GCS concludes that the financial provision calculations provided by Atha-Africa Ventures are "incomplete and insufficient" to protect and rehabilitate the environment. The report specifically identifies two major omissions: the "rehabilitation of the surface area" regarding wetland rehabilitation and offsetting, and the "post closure management of residual and latent environmental impacts," such as the decant of polluted water.
  • The assessment of the Yzermyn mine location indicates significant environmental sensitivities, particularly regarding headwater wetlands. The report states that significant residual impacts, rated as "moderately-high to high," will occur that cannot be reduced to acceptable levels through onsite mitigation alone, necessitating the use of wetland offsets.
  • The report proposes specific conservative cost estimates for wetland offsets, including upfront costs of R150,000 per hectare for land purchase, R500,000 for planning and proclamation, and R100 per meter for fencing. Annual management costs are estimated at R5,000 per hectare, with a detailed wetland offset plan estimated to cost between R200,000 and R300,000.
  • GCS emphasizes that costs for wastewater treatment are critical for environmental protection and should be provisioned for at least 20 years after decant as a conservative limit. The report provides a detailed cost table (Appendix B) showing that the present value of the trust fund required for closure and post-closure costs increases significantly over time, reaching over R16 billion by 2110.

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APA
Meyer, S. (2019). Review of the Yzermyn Financial Provision for the Centre for Environmental Rights Report. Centre for Environmental Rights. https://cer.org.za/wp-content/uploads/2019/10/Annexure-U-Yzermyn-Financial-Provision-Review.pdf?x21779
Chicago
Meyer, Sharon. Review of the Yzermyn Financial Provision for the Centre for Environmental Rights Report. Centre for Environmental Rights, 2019. https://cer.org.za/wp-content/uploads/2019/10/Annexure-U-Yzermyn-Financial-Provision-Review.pdf?x21779.
Wikipedia
{{cite report |last1=Meyer |first1=Sharon |title=Review of the Yzermyn Financial Provision for the Centre for Environmental Rights Report |publisher=Centre for Environmental Rights |date=9 September 2019 |url=https://cer.org.za/wp-content/uploads/2019/10/Annexure-U-Yzermyn-Financial-Provision-Review.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{meyer2019review, author = {Meyer, Sharon}, title = {{Review of the Yzermyn Financial Provision for the Centre for Environmental Rights Report}}, institution = {Centre for Environmental Rights}, year = {2019}, month = sep, url = {https://cer.org.za/wp-content/uploads/2019/10/Annexure-U-Yzermyn-Financial-Provision-Review.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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