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A notice of appeal submitted by BirdLife South Africa to the Minister of Mineral Resources on 30 July 2013, challenging the Director-General's decision to grant a mining right (MP 30/5/1/2/2/505 MR) to William Patrick Bower (Pty) Ltd for coal mining in the Belfast district of Mpumalanga Province.

This document consists of several annexures related to two proposed coal mining projects in Mpumalanga, South Africa: the Lusthof Colliery and the WPB Colliery. The first part is a draft report from 2012 by Dr. Hugo van Zyl for Black Gold Coal Estates (BGCE) regarding the financial provisioning for a Reverse Osmosis Water Treatment Plant (WTP) at Lusthof Colliery, estimating a required provision of approximately R74.42 million to cover construction and 100 years of post-closure operation. The second part contains correspondence and reviews from 2013 to 2015 regarding the WPB Colliery, featuring objections from BirdLife South Africa and technical reviews by Golder Associates. These reviews highlight 'fatal flaws' in the WPB Colliery's water use license application, specifically the lack of adequate acid mine drainage (AMD) assessment, insufficient public participation, and flawed geochemical modelling for pollution mitigation.

This document is a response filed by UX Inc. on behalf of William Patrick Bower (Pty) Ltd (WPB) to an appeal lodged by Birdlife South Africa against the granting of a mining right. WPB argues that the appeal is out of time, that Birdlife South Africa lacks standing, and that the environmental concerns raised are based on outdated data and ignore the fragmented state of the land due to historical farming.