IWULA, IWUL and Specialist Studies Review of the proposed Yzermyn Colliery Mpumalanga

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 subsequent 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 granted without a sufficient understanding of the environmental impacts or the interconnection between water resources.

• The groundwater model developed by Delta h (2014) is considered to have low confidence (Class 1) and is unsuitable for the sensitive environment of the Yzermyn mine. The model was run in steady state, meaning it cannot quantify seasonal variations in groundwater levels or the resulting impacts on springs and baseflow.
• There is a critical lack of site-specific hydrogeological data regarding dolerite sills, dykes, and faults, which significantly influence groundwater flow. Consequently, claims that the dolerite sill would prevent the dewatering of wetlands are unsupported by scientific evidence.
• The proposed mine is likely to cause significant drawdown in the shallow and deep aquifers, which would lead to the drying up of groundwater-dependent ecosystems, including springs and wetlands, above the underground workings. Some wetlands could remain dry for up to 60 years (15 years of operation plus 45 years for water levels to rebound).
• Wetland assessments conducted by SAS were inadequate because they relied on dry-season fieldwork and desktop delineations for the underground mining area. A Level 1 assessment (desktop with limited verification) was used instead of the required Level 2 assessment for such a sensitive area.
• The report identifies a material gap regarding post-closure water management. While mine water decant is expected, there is no information on the capital (capex) or operational (opex) costs of a water treatment plant required post-closure, which is essential for determining the mine's financial viability.
• The Integrated Water Use License (IWUL) is fundamentally flawed because it does not authorize the discharge of treated water post-closure, only the operational phase discharge. Furthermore, the license incorporates specialist reports by reference rather than listing specific, enforceable mitigation measures.
• The hydrological assessments are based on outdated layouts and fail to comply with General Notice 704 (GN 704) regarding the delineation of a flood line Exclusion Zone. Additionally, the Pollution Control Dam (PCD) is likely undersized due to the use of inaccurate rainfall data.
• The mine is located in a threatened ecosystem (Wakkerstroom/Luneburg Grasslands) and near protected environments, yet the impacts on biodiversity—including noise and light pollution affecting protected bats and avifauna—have not been properly quantified.

APA

Koning, A., Bredenkamp, B., King, K., & Langlands, K. (2017). IWULA, IWUL and Specialist Studies Review of the proposed Yzermyn Colliery Mpumalanga. Centre for Environmental Rights. https://cer.org.za/wp-content/uploads/2019/09/Annexure-V_-GCS-Review.pdf?x21779

Chicago

Koning, Alvar, Brendon Bredenkamp, Karen King, and Kate Langlands. IWULA, IWUL and Specialist Studies Review of the proposed Yzermyn Colliery Mpumalanga. Centre for Environmental Rights, 2017. https://cer.org.za/wp-content/uploads/2019/09/Annexure-V_-GCS-Review.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 Studies Review of the proposed Yzermyn Colliery Mpumalanga |publisher=Centre for Environmental Rights |date=1 December 2017 |url=https://cer.org.za/wp-content/uploads/2019/09/Annexure-V_-GCS-Review.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{koning2017iwula, author = {Koning, Alvar and Bredenkamp, Brendon and King, Karen and Langlands, Kate}, title = {{IWULA, IWUL and Specialist Studies Review of the proposed Yzermyn Colliery Mpumalanga}}, institution = {Centre for Environmental Rights}, year = {2017}, month = dec, url = {https://cer.org.za/wp-content/uploads/2019/09/Annexure-V_-GCS-Review.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }