atha-africa-replying-submission-in-terms-of-regulation-747-of-the-mprda-regulations-8-august-2019-70752ba425e764ac.pdf

This document is a replying submission by Atha-Africa Ventures (Pty) Ltd to the Director-General of the Department of Mineral Resources. It responds to an administrative appeal lodged by a coalition of environmental organisations against the approval of the Environmental Management Programme (EMP) for the Yzermyn Underground Coal Mine Project.

• Atha-Africa argues that the Department of Mineral Resources (DMR) approved the EMP based on a 'worst case scenario' because the initial application included a discard dump and washing plant that were later excluded in parallel applications under NEMA and the NWA.
• The Yzermyn Project is estimated to have proven coal resources of 104 million in situ tons, with an initial capital investment of approximately R 950 million and an expected revenue investment of R 12.94 billion into South Africa over the first 10 years.
• The project is designed to produce approximately 2.25 million tonnes of saleable product per year, create over 500 new jobs, and has a conservative economic life-of-mine of 15 years, potentially extending to 22-25 years.
• Atha-Africa asserts that the Appellants' claims regarding environmental impacts are based on an outdated September 2013 NSS Report and a flawed WSP groundwater model that overestimated hydraulic connectivity between aquifers.
• The company claims that the underground mining area does not coincide with wetland areas as it is located underground, and that surface infrastructure impacts on wetlands are limited to areas already disturbed by historical agricultural activities.
• Atha-Africa states that the project is located within the Mabola Protected Environment, but argues that commercial mining is lawful there with the required ministerial permission under section 48 of the NEM:PAA.
• The submission argues that the project complies with the Mining and Biodiversity Guideline (2013) by utilizing underground mining in a clearly defined spatial area and implementing specific mitigation measures.
• Regarding employment, Atha-Africa anticipates 70 jobs during the construction phase and up to 576 employees during the operational phase, though it notes that skilled labour may need to be sourced regionally, nationally, or from India due to low local skill levels.
• Atha-Africa contends that the administrative appeal's success would render the Mining Right futile and result in the loss of foreign investment, damaging investor confidence in South Africa.

APA

Centre for Environmental Rights (n.d.). atha-africa-replying-submission-in-terms-of-regulation-747-of-the-mprda-regulations-8-august-2019-70752ba425e764ac.pdf. https://cer.org.za/wp-content/uploads/2019/09/Atha-Africa-Replying-Submission-in-terms-of-Regulation-747-of-the-MPRDA-Regulations-8-August-2019.pdf?x21779

Chicago

Centre for Environmental Rights. atha-africa-replying-submission-in-terms-of-regulation-747-of-the-mprda-regulations-8-august-2019-70752ba425e764ac.pdf. n.d. https://cer.org.za/wp-content/uploads/2019/09/Atha-Africa-Replying-Submission-in-terms-of-Regulation-747-of-the-MPRDA-Regulations-8-August-2019.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=atha-africa-replying-submission-in-terms-of-regulation-747-of-the-mprda-regulations-8-august-2019-70752ba425e764ac.pdf |url=https://cer.org.za/wp-content/uploads/2019/09/Atha-Africa-Replying-Submission-in-terms-of-Regulation-747-of-the-MPRDA-Regulations-8-August-2019.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndathaafricareplyingsubmissionintermsofregulation747ofthemprdaregulations8august201970752ba425e764acpdf, author = {{Centre for Environmental Rights}}, title = {{atha-africa-replying-submission-in-terms-of-regulation-747-of-the-mprda-regulations-8-august-2019-70752ba425e764ac.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2019/09/Atha-Africa-Replying-Submission-in-terms-of-Regulation-747-of-the-MPRDA-Regulations-8-August-2019.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }