SUPPLEMENTAL EXPERT REPORT OF DR. RANAJIT (RON) SAHU EVALUATING THE UPDATED AIR QUALITY IMPACT ASSESSMENT FOR THE PROPOSED LEPHALALE COAL MINE

This document consists of two distinct parts: a supplemental expert report by Dr. Ranajit (Ron) Sahu evaluating the air quality impact assessment (AQIA) for the proposed Lephalale Coal Mine, and a comprehensive Spatial Development Framework (SDF) for the Lephalale Local Municipality. Dr. Sahu concludes that the mine will cause substantial adverse particulate matter (PM) impacts, exceeding national standards even with mitigation. The SDF section provides a long-term spatial plan for the municipality, focusing on the 'energy hub' of Africa, rural development, and the management of urban sprawl and environmental protection.

• Dr. Ranajit Sahu concludes that the Updated Air Quality Impact Assessment (AQIA) confirms that particulate matter (PM) emissions from the proposed Lephalale Mine will be significantly above standards and very adverse, even with maximum efficiency mitigation measures.
• The Updated AQIA predicts that PM2.5 24-hour average concentrations will exceed the national daily standard of 40μg/m3 up to approximately 8 km from the mine footprint, and annual average concentrations will exceed the national standard of 20μg/m3 within the footprint and up to 1 km to the west.
• Dr. Sahu identifies several flaws in the Updated AQIA, including the continued use of poorly-rated US EPA AP-42 emission factors, a lack of engineering design support for assumed mitigation efficiencies, and the omission of Total Suspended Particulates (TSP) data.
• The Lephalale Local Municipality's spatial strategy identifies a hierarchy of nodes, including the Provincial Growth Point (Lephalale/Onverwacht/Marapong), a Municipal Growth Point (Thabo Mbeki), and Rural Service Delivery Points (Ga-Seleka and Shongoane).
• The municipality faces significant urban sprawl and housing speculation, with 54% of stands in the Ellisras/Marapong area remaining vacant. To combat this, the SDF proposes a 'vacant residential land' tariff to discourage speculation.
• The SDF emphasizes the 'energy hub' role of Lephalale, driven by coal mining and power stations such as Medupi and Matimba, while warning that mining is a temporary land use that can lead to 'ghost towns' if not integrated into a sustainable human settlement plan.
• The Rural Focus Area is prioritized for 'Agri-Park' development, including the establishment of Farmer Production Support Units (FPSU) in Ga-Seleka, Thabo Mbeki, and Shongoane to support livestock, poultry, and vegetable production.
• Environmental protection is a core pillar of the SDF, with the identification of Critical Biodiversity Areas (CBAs) and Ecological Support Areas (ESAs), and the designation of the Waterberg Biosphere Reserve as a key conservation area.
• The municipality's Capital Expenditure Framework (CEF) for 2017-2020 allocates the vast majority of its R833 million budget to road infrastructure, accounting for 77.77% of total spending.
• Flood risk is a significant concern in the Rural Focus Area, with a 1:100 year flood line study indicating that approximately 1,500 structures are at risk, particularly in Thabo Mbeki (832 structures) and Beauty (174 structures).

APA

Sahu, R. (. (2024). SUPPLEMENTAL EXPERT REPORT OF DR. RANAJIT (RON) SAHU EVALUATING THE UPDATED AIR QUALITY IMPACT ASSESSMENT FOR THE PROPOSED LEPHALALE COAL MINE. Centre for Environmental Rights. https://cer.org.za/wp-content/uploads/2024/10/Reply-to-LCM-with-annexures.pdf?x21779

Chicago

Sahu, Ranajit (Ron). SUPPLEMENTAL EXPERT REPORT OF DR. RANAJIT (RON) SAHU EVALUATING THE UPDATED AIR QUALITY IMPACT ASSESSMENT FOR THE PROPOSED LEPHALALE COAL MINE. Centre for Environmental Rights, 2024. https://cer.org.za/wp-content/uploads/2024/10/Reply-to-LCM-with-annexures.pdf?x21779.

Wikipedia

{{cite report |last1=Sahu |first1=Ranajit (Ron) |title=SUPPLEMENTAL EXPERT REPORT OF DR. RANAJIT (RON) SAHU EVALUATING THE UPDATED AIR QUALITY IMPACT ASSESSMENT FOR THE PROPOSED LEPHALALE COAL MINE |publisher=Centre for Environmental Rights |date=26 August 2024 |url=https://cer.org.za/wp-content/uploads/2024/10/Reply-to-LCM-with-annexures.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{sahu2024supplemental, author = {Sahu, Ranajit (Ron)}, title = {{SUPPLEMENTAL EXPERT REPORT OF DR. RANAJIT (RON) SAHU EVALUATING THE UPDATED AIR QUALITY IMPACT ASSESSMENT FOR THE PROPOSED LEPHALALE COAL MINE}}, institution = {Centre for Environmental Rights}, year = {2024}, month = aug, url = {https://cer.org.za/wp-content/uploads/2024/10/Reply-to-LCM-with-annexures.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }