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This document is a written response from Atha-Africa Ventures (Pty) Ltd (the Second Respondent) to a substituted appeal submitted on 1 December 2017. The appeal, lodged by the Endangered Wildlife Trust, the Federation for a Sustainable Environment, and Mpumalanga Landbou/Agriculture, challenges the Director-General of the Department of Water and Sanitation's decision to grant a water use licence for the Yzermyn Project. Atha-Africa argues that the Appellants rely on outdated reports and a misunderstanding of the precautionary principle, asserting that the project's environmental impacts are localised, manageable through mitigation, and balanced by significant socio-economic benefits.

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.