Review of Environmental Impact Assessment Report & Environmental Management Programme, and Environmental Authorisation, for Yzermyn underground coal project

The review concludes that the Yzermyn underground coal project's EIAR and EMPr are of poor quality, failing to address critical concerns from the Department of Environmental Affairs (DEA), Department of Water Affairs (DWA), and Department of Mineral Resources (DMR). The author argues that the project poses high risks to 'irreplaceable' biodiversity and water resources, specifically regarding acid mine drainage and the drawdown of wetlands. The review asserts that the competent authority ignored these risks and the NEMA principles when granting environmental authorisation, focusing only on surface footprint rather than landscape-scale impacts.

• The review concludes that the EIAR failed to meet the requirements set by the Department of Environmental Affairs (DEA) in its 16 May 2014 rejection letter, and did not adequately address concerns from the Department of Water Affairs (DWA) or the Department of Mineral Resources (DMR).
• The project is located in an extremely sensitive area with 'irreplaceable' and 'optimal' Critical Biodiversity Areas, and the review argues that the project is 'fatally flawed' due to its potential for high and long-term impacts on biodiversity and water resources.
• There is a high risk of acid mine drainage (AMD) and post-closure decant that could substantially increase pollutant concentrations in surface and groundwater, with stabilisation potentially taking up to 45 years.
• The EIAR inappropriately focused on the direct 'footprint' of surface infrastructure (approximately 22.4 ha) while ignoring indirect and cumulative impacts on wider ecosystems, including the potential drying up of wetlands within the drawdown cone.
• The review identifies significant gaps in technical data, noting that groundwater models were based on limited dry-season data and lacked confidence in predictions regarding recharge rates and hydraulic conductivities.
• The Environmental Management Programme (EMPr) is described as poor and vague, lacking explicit management targets and providing inadequate monitoring, such as recommending groundwater monitoring for only two years post-closure despite decant risks lasting decades.
• The review asserts that the competent authority failed to apply the National Environmental Management Act (NEMA) principles of sustainable development and ignored the 2014 national guidelines for wetland offsets.
• The project's 'need and desirability' is questioned, with the author arguing that the claim that coal is a prerequisite for energy demand is flawed given the 2015 Paris Agreement and declining global demand for thermal coal.
• The review claims the Environmental Assessment Practitioner (EAP) may not be legally registered with the SA Council for Natural Scientific Professions (SACNASP) and failed to integrate specialist findings objectively.

APA

Brownlie, S. (2016). Review of Environmental Impact Assessment Report & Environmental Management Programme, and Environmental Authorisation, for Yzermyn underground coal project. Centre for Environmental Rights. https://cer.org.za/wp-content/uploads/2011/12/Annexure-E-1.pdf?x21779

Chicago

Brownlie, Susie. Review of Environmental Impact Assessment Report & Environmental Management Programme, and Environmental Authorisation, for Yzermyn underground coal project. Centre for Environmental Rights, 2016. https://cer.org.za/wp-content/uploads/2011/12/Annexure-E-1.pdf?x21779.

Wikipedia

{{cite report |last1=Brownlie |first1=Susie |title=Review of Environmental Impact Assessment Report & Environmental Management Programme, and Environmental Authorisation, for Yzermyn underground coal project |publisher=Centre for Environmental Rights |date=17 August 2016 |url=https://cer.org.za/wp-content/uploads/2011/12/Annexure-E-1.pdf?x21779 |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{brownlie2016review, author = {Brownlie, Susie}, title = {{Review of Environmental Impact Assessment Report \& Environmental Management Programme, and Environmental Authorisation, for Yzermyn underground coal project}}, institution = {Centre for Environmental Rights}, year = {2016}, month = aug, url = {https://cer.org.za/wp-content/uploads/2011/12/Annexure-E-1.pdf?x21779}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }