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part-2-of-atha-africa-replying-submission-in-terms-of-regulation-747-of-the-mprda-regulations-8-august-2019-4e2322ae8658724c.pdf
This document is a replying submission by Atha-Africa, submitted on 12 April 2019, responding to an administrative appeal against the approval of the Environmental Management Programme (EMP) for the Yzermyn Project. The submission disputes the findings of a September 2013 NSS Report and a subsequent 'Brownlie Review,' arguing that updated specialist studies by Delta-H and Scientific Aquatic Services demonstrate that the project's environmental impacts—specifically regarding wetlands, groundwater, and biodiversity—are localized and can be effectively mitigated.
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Document type: Report
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