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This document is a legal affidavit and supporting evidence filed by the Centre for Environmental Rights (CER) on behalf of a coalition of environmental organisations. It seeks the review and setting aside of decisions made by a Municipal Planning Tribunal and a Municipal Appeal Authority regarding a land-use change application by Atha-Africa Ventures (Pty) Ltd for the proposed Yzermyn underground coal mine. The applicants argue that the decisions were irrational, procedurally unfair, and failed to consider the strategic environmental and hydrological significance of the area, specifically its location within a Strategic Water Source Area (SWSA) and the Mabola Protected Environment.

This report examines land-use management in the Lephalale Local Municipality, focusing on the challenges of a municipality that owns almost no land within its urban edge. It details the municipality's strategies for land acquisition, the provision of integrated human settlements, and the incremental introduction of land-use schemes in rural areas under traditional authorities, specifically the Seleka Traditional Authority. The document highlights the influence of major mining and energy companies, the impact of the Spatial Planning and Land Use Management Act (SPLUMA), and the complexities of intergovernmental relations.