The following comments are submitted on behalf of the Federation for Sustainable Environment (FSE) pursuant to the hearings by the Parliamentary Portfolio Committee on Environmental Affairs, which were held at Machavie, Matlwang Community Hall, Tlokwe Local Municipality on the 13th of September, 2014 and on invitation of the honourable Chairperson of the PPC on Environmental Affairs, the honourable Mr. Jackson Mthembu.
Mining is an important contributor to the South African economy but has the potential for significant negative impacts on the environment.
The impacts and costs associated with rehabilitation of mining operations after closure including the cost to human and environmental health and the social legacy of people employed, supported, and attracted to the mine and its surrounding areas are often delayed, and accumulate for decades after mineral extraction. These costs are not internalized but are borne by communities, a mute environment and future generations and not by the mining industry as would be expected. Called negative externalities, these deflected costs of mining are held artificially low while the benefits are exaggerated.
we respectfully appeal to the honourable Chairperson and Members of the PPC on Environmental Affairs, and the honourable officials within the Department of Environmental Affairs to, in the cost/benefit analysis, consider the costs associated with the life-time of the impacts and not only the costs associated with the impacts during the life-time of the mine, since the impacts may continue for hundreds of years after mine closure. In the absence of government interventions to compel mining companies to internalize their negative impacts, the social and environmental costs will be absorbed by the surrounding communities and other stakeholders. The externalization of costs to communities, particularly to the poor and disadvantaged, is conceived as unfair, inequitable and unpalatable, and in contravention of the polluter pays principle.
There is currently a lack of evidence that offsets are effective and actually achieving their intended outcomes. Many experts agree that there is a dearth of evidence to show that offset schemes actually achieve the intended biodiversity outcomes and that the case for offsets to achieve a positive conservation outcome has not been made.
The Western Limb of the Bushveld Igneous complex, which includes the Greater Pilanesberg Area, is endowed with 80% of the world’s platinum and platinum group metals. The intense mining activities within the Greater Pilanesberg Area, however cause various environmental impacts due to externalities; these are impacts that place strains and limitations on the use of other natural assets beyond the mere extraction of platinum. These externality effects include impacts upon the quality and quantity of water, land use potential, sense of place, biodiversity the conservation potential of the area, and significant risks to the sustainability of tourism and eco-tourism within the region and future post-closure land-uses.
Issues pertaining to water
The Water Services Act and the National Water Act were designed to achieve the following:
[...] redress the inequalities of racial and gender discrimination of the past; link water management to economic development and poverty eradication; and ensure the preservation of the ecological resource base for future generations.
Many mining communities within the North West Province remain without access to water while some mines continue to modify the water table and divert river systems without water use licenses, with impunity.
More water is allocated for supply purposes than is feasible from an ecological, tourism and the communities’ requirements perspective.
The urgent need to meet the water demands of the mining industry within the unique Pilanesberg area has outweighed the rights of the rural poor to access to enough water to meet their basic human rights (e.g. drinking and food preparation), the rights of eco-tourism and tourism, which will provide post closure sustainable economic growth and job creation, and the right of the environment. This, we respectfully submit, has to be rectified.
The Department of Water Affairs’ National Water Resource Strategy-2 found that in 2025 all four international river basins will transition into Absolute Water Scarcity. This suggests that transboundary River Basins will become the focal point of future hydropolitical risks and economic viability with particular reference to the Limpopo, which likely will be the epicentre of sub-national economic stagnation and social decay.
The Limpopo River Basin, already over-allocated by about 120%, has an extremely high Water Crowding Index (i.e. 2000 persons per flow unit per year), and is facing a 241% increase in demand by 2025, that is more than 2.5 times the global norm for social cohesion.
The Department of Water Affairs’ Classification of Significant Water Resources in the Crocodile (West) Marico WMA and Matlabas and Mokolo Catchments: Limpopo WMA (WP 10506) Classification Report found that there will be a dramatic increase in water demands as a result of:
- Current mining activities and proposed mining activities;
- Sasol’s proposed Maphuta coal to liquid fuel projects;
- The exploitation of the vast coal reserves in the Waterberg;
- Exxaro’s Grootegeluk Colliery (largest open cast coal mine of its kind in the world);
- The expansion of the Grootegeluk mine to supply the new Medupi Power Station with coal; and
- Matimba and Medupi three new Eskom power stations in the future. (Pages 3 and 4 of the Classification Report.)
While the current revised water balance in terms Department of Water Affairs’ Status Report on the supply of water within the Crocodile West/Marico “continues to indicate a growing surplus of water in the system originating from growing treated wastewater generated in the urban areas of Northern Gauteng,” uncertainties remain.
The Department of Water Affairs also recognises the fact that “tourism plays an important role in stimulating accommodation, transport and retail sectors” and that “the tourism economy of the study area is an important contributor to regional GDP.” Significant tourism and eco-tourism opportunities and conservation opportunities are associated with Sun City, the Pilanesberg National Park, Madikwe National Park and the proposed Heritage Park within the unique Pilanesberg area.
Post-mining land use
The extractive industry is by its very definition unsustainable since it depletes a non-renewable resource. Mineral exploitation furthermore causes significant land use changes, generally irreversible destruction of ecosystems and loss in land capability.
Tourism and eco-tourism, on the other hand, are sustainable land uses and provide opportunities for sustainable job creation and economic growth in the post closure phase of the mines but unless the extent of cumulative and regional mining-related impacts on inter alia water resources, sense of place, biodiversity, air quality and soil within the Pilanesberg Area are factored in, in the approval of new mining rights and authorisation of environmental impact assessments and environmental management programmes, sustainable land use with associated water use in the post mine closure scenario will not be possible. The outcomes will result in economic and job stagnation, which will worsen poverty, and which will result in social decay.
- Establish a regional mine closure strategy for the mines within the Western Limb of the Bushveld Igneous complex, including the Greater Pilanesberg Area in order to ensure sustainable development through mining. The current level of mine closure practice in South Africa shows that an urgent need for a holistic approach to closure planning.
- Determine the ecological reserve for the Crocodile West/Marico Water Management Area with the aim of promoting a strategic approach to water management at mining and processing sites to ensure water is managed efficiently and that the requirements of the ecology, tourism, eco-tourism and communities are sufficiently met.
- Determine the resource quality objectives of the rivers, wetlands, dams and groundwater within the Crocodile West/Marico Water Management Area
- Declare certain areas within the Western Limb of the Bushveld Igneous Complex as irreplaceable conservation and biodiverse areas in order to protect the high conservation potential and biodiversity of the area. The Pilanesberg region has a unique eco-tourism, tourism and conservation potential. These sustainable land uses are facing significant risks from environmentally deleterious activities, especially mining. The Pilanesberg National Park falls within a National Freshwater Ecosystem Priority Area, yet there are significant mining and proposed mining activities within this sensitive area. Open cast mining is particularly damaging to the environment and is consequently incompatible with environmental conservation. The importance of conserving tourism, conservation and eco-tourism is emphasized in the Moses Kotane Local Municipality’s Integrated Development Plans for 2013/2014.
- Establish an Environmental Management Framework for the region.