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

The review concludes that the specialist reports for the Yzermyn underground coal mine are insufficient, failing to identify all environmental impacts and the interconnection between hydrogeology, hydrology, and wetlands. Consequently, the issued IWUL lacks sufficient conditions to mitigate impacts to an acceptable standard. Key failures include a low-confidence groundwater model (Class 1) that cannot quantify seasonal variations, a lack of field-based wetland delineation for the underground mining area, and the absence of a post-closure water treatment cost analysis. The report highlights that mine dewatering will likely cause significant drawdown in shallow and deep aquifers, potentially drying up high-value wetlands and springs, while post-closure acid mine drainage (AMD) and contaminant plumes remain unsimulated and unquantified.

• The groundwater model developed by Delta h (2014) is classified as a Class 1 model, meaning it has "relatively low confidence associated with any predictions". It is unsuitable for the Yzermyn site because it was run in steady state and cannot quantify "seasonal variations in groundwater levels" or the seasonal impacts on springs and baseflow.
• There is a critical lack of hydrogeological data regarding the dolerite sills, dykes, and faults in the mining area. This is a "material gap in the environmental assessments" because these features significantly influence groundwater flow and modelling results, yet their lateral extent and hydrological properties remain unknown.
• The mine's dewatering process is expected to create cones of drawdown in both shallow and deep aquifers, which will negatively impact groundwater-dependent ecosystems. GCS asserts that all wetlands situated above the underground workings fed by groundwater "would dry up as a result of the dewatering effects of the mine".
• Wetland assessments conducted by SAS were inadequate as they relied on a "Level 1 assessment" (desktop evaluation with limited field verification) and were primarily conducted during the dry season. Furthermore, wetlands within the underground mining boundary were not delineated through fieldwork, only at a "desktop wetland delineation" level.
• The report identifies a failure to assess post-closure risks, specifically the lack of simulation for a "groundwater contaminant plume" and the absence of a geochemical model to predict long-term water quality trends. Post-closure decant is expected, but no capital (capex) or operational (opex) costs for a required water treatment plant were provided.
• The Pollution Control Dam (PCD) sizing is considered inaccurate because it is based on a low-confidence groundwater model and inconsistent rainfall data. GCS notes that the current designs may cause the PCD to spill, which is unacceptable in this "environmentally-sensitive area".
• The issued IWUL is fundamentally flawed because it incorporates specialist recommendations by reference without reconciling contradictions or listing specific requirements. It fails to authorize a key water use: the discharge of treated water post-closure, as the license only covers operational phase discharge volumes.
• The proposed mine is located in a "threatened ecosystem" (Wakkerstroom/Luneburg Grasslands) and near protected environments. The review concludes that the impacts on this ecosystem, including the loss of high-value wetlands and the effect of noise and light pollution on avifauna and bats, have not been sufficiently analyzed.

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} }