part-2-of-atha-africa-replying-submission-in-terms-of-regulation-747-of-the-mprda-regulations-8-august-2019-4e2322ae8658724c.pdf

This document is a replying submission by Atha-Africa, submitted on 12 April 2019, responding to an administrative appeal against the approval of the Environmental Management Programme (EMP) for the Yzermyn Project. The submission disputes the findings of a September 2013 NSS Report and a subsequent 'Brownlie Review,' arguing that updated specialist studies by Delta-H and Scientific Aquatic Services demonstrate that the project's environmental impacts—specifically regarding wetlands, groundwater, and biodiversity—are localized and can be effectively mitigated.

• Atha-Africa asserts that the wetlands within the proposed surface infrastructure area are of limited ecological importance, described as 'hillslope seeps' that are 'highly marginal' and 'highly disturbed' due to historical farming, grazing, and fires.
• The project's surface infrastructure layout was re-engineered to reduce the direct impact on wetlands from an initial area of 24.2 ha to 10.36 ha, with only 4.4 ha of that area remaining undisturbed by ploughing.
• Atha-Africa disputes the validity of the September 2013 NSS Report, claiming it relied on a theoretical groundwater model by WSP that assumed a high degree of hydraulic connectivity between aquifers, which was later contradicted by a 'ground-truthed' model by Delta-H.
• The Delta-H geohydrological study concluded that there is low hydraulic connectivity between the shallow weathered Karoo aquifer and the deeper fractured Karoo aquifer, meaning the 'cone of dewatering' from mining is expected to be more pronounced in the deeper aquifer and less likely to affect surface wetlands.
• Atha-Africa argues that the risk of acid mine drainage (AMD) is low because historical mines in the same coal formation show virtually no AMD, and the project has removed the wash plant and discard facilities, which are the primary sources of AMD risk in Utrecht coal seams.
• To mitigate potential water contamination and AMD, Atha-Africa committed to a water treatment system that will treat water during construction, operation, and post-closure (decant) phases before release into surface resources.
• The submission claims that the impact on birdlife is negligible, noting that while the project is within an Important Bird Area, the affected surface area is only 22.4 hectares compared to the total area of the bird area which covers approximately 800 farms.
• Atha-Africa dismisses the 'Brownlie Review' as a 'mere desktop review' conducted by a non-specialist who lacked practical experience in mitigation measures and did not perform field investigations.
• The document states that the project's Environmental Management Programme (EMP) was approved on 28 June 2016 and a Water Use Licence was issued on 7 July 2016, indicating that the Department of Water and Sanitation (DWS) and the Department of Mineral Resources (DMR) were satisfied with the mitigation plans.

APA

Centre for Environmental Rights (n.d.). part-2-of-atha-africa-replying-submission-in-terms-of-regulation-747-of-the-mprda-regulations-8-august-2019-4e2322ae8658724c.pdf. https://cer.org.za/wp-content/uploads/2019/09/Part-2-of-Atha-Africa-Replying-Submission-in-terms-of-Regulation-747-of-the-MPRDA-Regulations-8-August-2019.pdf?x21779

Chicago

Centre for Environmental Rights. part-2-of-atha-africa-replying-submission-in-terms-of-regulation-747-of-the-mprda-regulations-8-august-2019-4e2322ae8658724c.pdf. n.d. https://cer.org.za/wp-content/uploads/2019/09/Part-2-of-Atha-Africa-Replying-Submission-in-terms-of-Regulation-747-of-the-MPRDA-Regulations-8-August-2019.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=part-2-of-atha-africa-replying-submission-in-terms-of-regulation-747-of-the-mprda-regulations-8-august-2019-4e2322ae8658724c.pdf |url=https://cer.org.za/wp-content/uploads/2019/09/Part-2-of-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

@techreport{centreforenvironmentalrightsndpart2ofathaafricareplyingsubmissionintermsofregulation747ofthemprdaregulations8august20194e2322ae8658724cpdf, author = {{Centre for Environmental Rights}}, title = {{part-2-of-atha-africa-replying-submission-in-terms-of-regulation-747-of-the-mprda-regulations-8-august-2019-4e2322ae8658724c.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2019/09/Part-2-of-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} }