(Reg. No. 2007/003002/08) NPO NUMBER 062986-NPO PBO No. (TAX EXEMPT) 930 039 506 Postnet Suite 87 Private Bag X033 RIVONIA 2128

COMMENTS ON NATIONAL GUIDELINE ON MINIMUM INFORMATION REQUIREMENTS FOR PREPARING ENVIRONMENTAL IMPACT ASSESSMENTS FOR MINING ACTIVITIES THAT REQUIRE ENVIRONMENTAL AUTHORISATION

The following comments are submitted on behalf of the Federation for Sustainable Environment (FSE) The FSE is a federation of community based civil society organisations committed to the realisation of the constitutional right to an environment that is not harmful to health or well-being, and to having the environment sustainably managed and protected for future generations. Their mission is specifically focussed on addressing the adverse impacts of mining and industrial activities on the lives and livelihoods of vulnerable and disadvantaged communities who live and work near South Africa’s mines and industries.

The FSE is a member of a significant number of governmental and academic forums, steering committees, task teams and teams of experts and its directors have two decades of experience with mining applications and environmental impact assessment processes.

DESIRED STATE OF THE ENVIRONMENT

The following comments are submitted on behalf of the Federation for Sustainable Environment (FSE) The FSE is a federation of community based civil society organisations committed to the realisation of the constitutional right to an environment that is not harmful to health or well-being, and to having the environment sustainably managed and protected for future generations. Their mission is specifically focussed on addressing the adverse impacts of mining and industrial activities on the lives and livelihoods of vulnerable and disadvantaged communities who live and work near South Africa’s mines and industries.  

The FSE’s comments, in line with its mission, are confined to the mining industry and in particular the platinum group metal producing mines in the Bonjanala Platinum District Municipality and mining applications and authorisation within the Marico River Catchment[1] and its impacts upon the environment and water resources. Our concerns, comments and recommendations are motivated by recent environmental authorisations of mining applications within areas of highest biodiversity importance and the profound often irreversible impacts on eco-systems and sustainable future land use with associated resources such as water.

[1] A number of applications for mining and prospecting has recently been authorised with the Marico River Catchment. The Groot Marico River is a key water resource, which is classified in the Ecological category A/B – largely natural.  The upper reaches of the Groot Marico River are a river FEPA due to its clean, free flowing nature where the vulnerable Marico barb is found.  The Quartenary Catchments A31A and A31B fall within a flagship NFEPA and the Catchment encompasses an Aquatic CBA 1 and terrestrial CBA. Certain areas within the catchment have already been declared protected areas and that the entire area is currently before UNESCO for consideration as a Biosphere Reserve. The river originates from the dolomitic eye of the Marico River (Kaalloog). The Groot Marico River forms the south-western headwaters of the Limpopo.  The Catchment is the pumphouse of the Limpopo river. The Groot Marico River provides water to hundreds of thousands of downstream water users and the Molatedi Dam, which supplies North West’s premier Big 5  Madikwe Game Reserve. The water is also pumped from the Tswasa Weir at the Dam to Gaberone in terms of the international Tswasa Agreement.