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A letter from Atha Africa Ventures (Pty) Ltd (AAV) to the Department of Mineral Resources (DMR) requesting amendments to the conditions of a granted Mining Right for the Yzermyn Underground Coal Project (YUCP) in Mpumalanga. AAV argues that current restrictions on mining in wetland areas are too restrictive and proposes alternative wording to allow for surface infrastructure and regulated wetland disturbance.

The assessment concludes that the Yzermyn underground coal mine is 'fatally flawed' from a biodiversity perspective and recommends a 'NO GO' decision. The project is located in a highly sensitive area, including the Enkangala Grassland Important Bird Area (IBA) and several Freshwater Ecosystem Priority Areas (FEPAs). Key risks include the potential for extensive wetland loss or deterioration due to groundwater drawdown (cones of depression) and long-term groundwater contamination from acid mine drainage (AMD) post-closure. The report highlights a significant disconnect between the findings of independent specialists—who identify high-significance impacts and irreplaceable habitats—and the Environmental Impact Assessment Report (EIAR), which downplays these risks by focusing narrowly on the surface infrastructure footprint. The assessment notes that the project threatens numerous 'Conservation Important' (CI) species of birds, mammals, reptiles, and amphibians.