MR BIRDLIFE SOUTH AFRICA’S RESPONSE TO WILLIAM PATRICK BOWER PTY LTD’S REPLYING SUBMISSION

This responding statement, submitted by the Centre for Environmental Rights on behalf of BirdLife South Africa, argues that a mining right granted to William Patrick Bower Pty Ltd (WPB) should be set aside. The document contends that WPB's replying submission was filed late and introduced new, unauthorized mine layout plans and hydrogeochemical data that were not available to the decision-maker at the time of the grant. BirdLife South Africa further asserts that the mining area contains endangered ecosystems and irreplaceable biodiversity, contradicting claims made by WPB.

• BirdLife South Africa argues that the replying submission from William Patrick Bower Pty Ltd (WPB) was submitted at least 94 days after the deadline prescribed in Regulation 74(7) and should be disregarded by the Minister of Mineral Resources.
• The document claims that WPB introduced a "hydrogeochemical study" from September 2013 and a "new, revised layout plan" (Opencast Layout 2013) that were not before the decision-maker when the mining right was granted, meaning the right was based on "outdated" and deficient information.
• BirdLife South Africa asserts that WPB's claim that the mining area is a "fragmented habitat" contradicts WPB's own environmental report, which identifies the area as a "sensitive environment" and notes that the Steenkampsberg Important Bird Area is of "global importance".
• The proposed mining area is identified as part of the Dullstroom Plateau Grasslands ecosystem, which is officially listed as an endangered ecosystem in Mpumalanga.
• The document reports that existing unrehabilitated coal mining sites on the property are already causing water pollution through acid mine drainage, which is evidenced by a metallic taste in borehole water and the refusal of livestock to drink from certain water courses.
• BirdLife South Africa defends the scientific validity of arguments made by Dr Lötter of the Mpumalanga Tourism and Parks Agency, stating they are based on the Mpumalanga Biodiversity Conservation Plan (MBCP), which utilizes a biodiversity database compiled over 21 years.

APA

Centre for Environmental Rights (n.d.). MR BIRDLIFE SOUTH AFRICA’S RESPONSE TO WILLIAM PATRICK BOWER PTY LTD’S REPLYING SUBMISSION. https://cer.org.za/wp-content/uploads/2011/12/BirdLife-responding-statement_complete.pdf?x21779

Chicago

Centre for Environmental Rights. MR BIRDLIFE SOUTH AFRICA’S RESPONSE TO WILLIAM PATRICK BOWER PTY LTD’S REPLYING SUBMISSION. n.d. https://cer.org.za/wp-content/uploads/2011/12/BirdLife-responding-statement_complete.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=MR BIRDLIFE SOUTH AFRICA’S RESPONSE TO WILLIAM PATRICK BOWER PTY LTD’S REPLYING SUBMISSION |url=https://cer.org.za/wp-content/uploads/2011/12/BirdLife-responding-statement_complete.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndbirdlife, author = {{Centre for Environmental Rights}}, title = {{MR BIRDLIFE SOUTH AFRICA’S RESPONSE TO WILLIAM PATRICK BOWER PTY LTD’S REPLYING SUBMISSION}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2011/12/BirdLife-responding-statement_complete.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }