An extract of the comprehensive comment follows below. The full comment is available in three parts from this site: Part 1, Part2, and Part 3
PUBLIC COMMENT ON Draft Regional Closure Strategy Of Mines On The West Rand And Far West Rand
Mariette Liefferink comments in her capacity as activist and whistleblower, and as the DWAF appointed convener of the public involvement and participation component of the rehabilitation of the Wonderfonteinspruit Catchment. She portrays grassroots level realities and the current infringements upon legal measures
She says that many factors influence the closure liabilities and costs, as well as environmental and societal impacts.
These factors include - “the current unvegetated status of the majority of tailings dams with resultant erosion, runoffs and toxic and radioactive dust fallout; open pits; silted up toe paddocks; open shafts; ponding of acidic mine water; tailings spillages; unfenced hazardous mining sites; unremediated sinkholes, some of massive proportions, unrehabilitated footprints of reprocessed tailings dams."
She infers that the mining industry is currently under severe economic constraints. Her inference is based on the current economic climate and the recent formation of a task team to mitigate the impact of the financial crisis on the local mining industry. She goes on to say that the survival of Harmony Gold, Mintails and DRD Gold, will be jeopardised further by the pumping and treatment costs of Acid Mine Drainage (AMD) within the West Rand. These costs will increase proportionally with the additional volumes needed to cope with higher rainfall periods.
Liefferink advises that responsible officials within the Depratment of Mineral and Energy (DME) give assiduous attention to alternative approaches for addressing the financial provision for mine rehabilitation and closure.
The ecological integrity of the Tweelopiespruit has been severely compromised by the discharge of treated and semi-treated acidic mine water. Liefferink says the remediation of the river system is a priority to protect the ecological integrity of the ecosystem and human health. Yet the funding is currently locked in a financial provision.
She explains, “The Minerals and Petroleum Resources Development Act (Act 28 of 2002) requires that a risk-based approach to determining the financial provision be adopted by the mining company. The object is to ensure that there are sufficient funds available at any stage in the life of a mine to cover the cost of rehabilitation and closure. The AMD decant within the West Rand is an emergency issue and the proposed solution for the AMD will form part of the regional closure strategy of the mines, but funds are currently locked up in the financial provision. Sound judgment and interpretation of the intent of the MPRDA regarding the use of trust funds are urgently called for."
Liefferink comments that to protect the ecological integrity of aquatic ecosystems and human health, a more comprehensive approach is necessary, one that focuses on the potential effects of chemical substances, rather than on the substance themselves.
“Community engagement ought to commence as early as possible in the development of the regional closure strategies. Exclusion of communities will further contribute to the mistrust and the conception of collusion between the mining industry and Government.
"Local communities, particularly the vulnerable and disadvantaged persons within the West Rand and Far West Rand, are ignorant of the environmental impacts, hazards and risks of gold mining within the West Rand and Far West Rand. There has been little or no effort by the mining companies or the State to raise awareness of environmental or health risks, or to develop the understanding, skills and capacity necessary for achieving equitable and effective participation in environmental decision making," says Liefferink.
She claims that negative perceptions of real or perceived environmental impacts within the West Rand and Far West Rand have been fuelled by an apparent unwillingness of regulators and of industry to discuss these impacts in public.
She recommends that public communication regarding mining related environmental impacts within the Wonderfonteinspruit Catchment be approached transparently. Further she advises that government departments and regulators take a proactive, and not a reactive stance in providing reliable information with sufficient detail to allow interested and affected parties to make informed decisions regarding their environment.
"The public needs to be warned of the potential hazards related to Derelict and Ownerless mine sites. Regrettably this is not done," Liefferink concludes.