OBJECTION TO TETRA4’s WATER USE LICENCE AMENDMENT APPLICATION FOR CLUSTER 2 EXPANSION

This document is a formal objection letter from the Centre for Environmental Rights (CER), on behalf of the Mining and Environmental Justice Community Network of South Africa (MEJCON-SA) and Mining Affected Communities United in Action (MACUA), regarding Tetra4's application to amend its Water Use Licence (WUL) for the Cluster 2 expansion of gas and helium production near Virginia, Free State. The document includes the original objections and the corresponding responses from Tetra4, focusing on risks to groundwater, radioactive contamination, waste management, and the impacts of climate change on water security.

• The proposed Cluster 2 expansion involves a significant increase in production scale, planning for up to 300 new production wells and 400 exploratory wells to produce up to 45 million cubic feet of natural gas per day.
• The project area relies on a 'sole source aquifer' for potable water, which CER argues is at risk of contamination from surface runoff, spills, and the migration of deep saline formation water (brine) through well drilling or historical boreholes.
• CER highlights a risk of radioactive contamination, noting that the Witwatersrand formation is known to contain uranium and that the project has not adequately evaluated formation water radioactivity or radium levels.
• There is a significant legacy of over 15,000 historical exploration wells in the study area, many of which may be unsealed and could act as conduits for contaminant transport; Tetra4 maintains that rehabilitating these third-party wells is not its legal responsibility.
• The objection notes that the Integrated Water and Waste Management Plan (IWWMP) fails to account for municipal water needed for dust suppression across 480 km of access roads, particularly under climate change scenarios that increase heat and dryness.
• The Matjhabeng municipality is experiencing a severe water crisis, with a Green Drop score for wastewater treatment facilities of 26% (down from 58% in 2013), which CER argues increases the vulnerability of local water resources.
• CER asserts that the project threatens the 'breadbasket of South Africa' (Free State Province), where maize and livestock production are highly vulnerable to the 3°C warming scenarios identified by the IPCC.

APA

Centre for Environmental Rights (2023). OBJECTION TO TETRA4’s WATER USE LICENCE AMENDMENT APPLICATION FOR CLUSTER 2 EXPANSION. https://cer.org.za/wp-content/uploads/2023/12/CER_letter_Table_BW_Final.pdf?x21779

Chicago

Centre for Environmental Rights. OBJECTION TO TETRA4’s WATER USE LICENCE AMENDMENT APPLICATION FOR CLUSTER 2 EXPANSION. 2023. https://cer.org.za/wp-content/uploads/2023/12/CER_letter_Table_BW_Final.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=OBJECTION TO TETRA4’s WATER USE LICENCE AMENDMENT APPLICATION FOR CLUSTER 2 EXPANSION |date=9 May 2023 |url=https://cer.org.za/wp-content/uploads/2023/12/CER_letter_Table_BW_Final.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrights2023objection, author = {{Centre for Environmental Rights}}, title = {{OBJECTION TO TETRA4’s WATER USE LICENCE AMENDMENT APPLICATION FOR CLUSTER 2 EXPANSION}}, institution = {Centre for Environmental Rights}, year = {2023}, month = may, url = {https://cer.org.za/wp-content/uploads/2023/12/CER_letter_Table_BW_Final.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }