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

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The review concludes that the Yzermyn underground coal project's EIAR and EMPr are of poor quality, failing to address critical concerns raised by the Department of Environmental Affairs (DEA), Department of Water Affairs (DWA), and Department of Mineral Resources (DMR). Key failures include the lack of updated specialist studies for the 'best environmental option', inadequate assessment of acid mine drainage (AMD) and its long-term decant risks, and a failure to account for cumulative impacts on 'irreplaceable' biodiversity and water resources. The reviewer asserts that the project's focus on surface 'footprint' impacts ignores wider landscape-scale damage to Freshwater Ecosystem Priority Areas (FEPAs) and the Grassland Important Bird Area. Furthermore, the review finds that the Environmental Authorisation was granted despite these deficiencies, relying on misleading information and failing to apply the NEMA principles of sustainable development.

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  • The EIAR failed to update specialist studies to assess the 'best environmental option' (the layout authorised on 7 June 2016), meaning the actual impacts of the approved project were not distinctly assessed.
  • There is a high risk of long-term acid mine drainage (AMD) and post-closure decant, with models suggesting it could take 45 years for mine voids to flood and that pollutant concentrations in surface waters would substantially increase.
  • The project is located in an extremely sensitive area containing 'irreplaceable' and 'optimal' Critical Biodiversity Areas, and the reviewer concludes the project is 'fatally flawed' due to its impact on these ecosystems.
  • The EIAR inappropriately focused on the direct surface 'footprint' of infrastructure (approximately 22.4 ha) while ignoring indirect and cumulative impacts on wider water-dependent ecosystems and FEPAs.
  • The project's location within the Grassland Important Bird Area, vital for 39 bird species of conservation importance, was not adequately addressed, specifically regarding the effects of noise, light, and habitat fragmentation.
  • The EMPr is considered poor and vague, lacking explicit management targets and providing inadequate monitoring (only two years post-closure) for a project with decant risks lasting decades.
  • The Environmental Authorisation was granted despite the EIAR's failure to apply the NEMA principles of sustainable development or consider national guidelines on wetland offsets and 'need and desirability'.
  • Socioeconomic assessments were biased in favour of mining, ignoring the potential long-term negative impacts on the existing nature-based tourism industry in Wakkerstroom, which supports about 400 jobs.

Cite the original document

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/2019/09/ET5.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/2019/09/ET5.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/2019/09/ET5.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/2019/09/ET5.pdf?x21779}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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