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Invitation by the DWS to participate in a working session regarding the draft National Water and Sanitation Master Plan: to be held on 2 February 2018 at the DBSA Conference Centre

Written by  Thursday, 25 January 2018 12:28
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The following preliminary comments on the National Water and Sanitation Master Plan (NW&SMP) 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.  

 

In accordance with the above-mentioned mission, the FSE’s comments are limited to matters pertaining to the mining industry. The FSE’s comments will be substantiated by real examples within the scope of the FSE’s experience and our active participation in a significant number of environmental impacts assessments, environmental management programme reports, water use license applications, environmental authorisations, steering committees, forums, task teams, teams of experts, academic research groups, boards, etc. over a period of 15 (fifteen years).

 

The FSE, with the support and representation of the Legal Resource Centre (LRC), is currently in the process of preparing additional comments on the NW&SMP.   In view of the aforesaid, we respectfully request allowance to refine and augment our preliminary comments.

 

The rest of the letter can be downloaded as a pdf.

MINING

OBJECTION TO THE AUTHORISATION OF THE PROSPECTING RIGHTS APPLICATION FOR LWENZHE RESOURCES - FILE REFERENCE NO. SAMRAD: NW

It is part of our law that the potential impact of a development on the sense of place of an area must be considered. In the case of Director: Mineral Development Gauteng Region and another v. Save the Vaal Environment and others 1999 (2) SA 709 (SCA) at 715C, the Supreme Court of Appeals with regard to a proposed mine on a wetland next to the Vaal river, identified as an environmental concern the “…predicted constant noise, light, dust and water pollution resulting from the proposed strip mine will totally destroy the ‘sense of place’ of the wetland and the associated Cloudy Creek. Thus the spiritual, aesthetic and therapeutic qualities associated with this area will also be eliminated.” This finding by the court established sense of place, as an environmental concern that can be impacted upon by development and that should be considered accordingly. The EAP failed to consider the impacts – as experienced by tourists - of the activity on the unique sense of place of the Pilanesberg National Park, the Kwa Maritane Lodge and Sun City. Sense of place has an economic value.

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Our dusty oasis

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WATER

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