The entire submission is available to download here, while an extract follows below.
WEST RAND BASIN
The situation with the West Rand Basin warrants the utmost urgency. The complexity is high and it cannot be solved in isolation.
The water emanating from the underground workings* has been demonstrated to have had a devastating impact on the surrounding surface water systems, in particular the Tweelopie Spruit which flows north from the goldfield, through the Krugersdorp Game Reserve and towards the Cradle of Humankind World Heritage Site.
In addition to the impacts on the surface water, localised impacts on groundwater have been identified in a dolomitic outlier immediately to the north of the mining area, while the migration of a plume, which could have a serious impact on the Cradle of Humankind, further to the north is suspected.The ramifications of AMD for the subregion are enormous.While the greatest focus in this regard is the Cradle of Humankind World Heritage Site, of no lesser, concern, are the downstream landowners and agricultural activities that are largely or wholly dependent on ground water for potable and economic use. Based on the possible water borne pollution and water toxicity, the communities at risk that are situated within the Tweelopiespruit Catchment (including the dolomitic aquifers and in particular the Zwartkrans Dolomitic Aquifer)
In recent years the environmental impact of mining impacts in the Witwatersrand have been in the public eye, with numerous press reports detailing real or perceived environmental disasters. To a large extent, negative perceptions of these impacts have been fuelled by an apparent unwillingness of regulators and to industry to discuss these impacts in public.It is recommended that public communication regarding mining related environmental impacts be approached transparently, but that government departments and regulators take a proactive stance in providing reliable information with sufficient detail to allow interested and affected parties to make informed decisions regarding their environment.
The main vehicles for public participation - ward committees and input into IDP processes - are fraught with problems.Ward committees tend to be highly political, reflecting local power and political elites, and not providing much voice to marginalized groups, and the IDP processes are overwhelmingly disempowering and technocratic.
In order for public participation to be more effective in practice there also needs to be a deconstruction of what is meant by "communities". While water policies and legislation promote the recognition of different types of water users and stress pro-poor policies, the structures and institutions established to facilitate meaningful participation need to take into account socio-economic differences and recognize that, all too often, the voices and input from the poorest communities are ignored.
DERELICT AND OWNERLESS MINES
The legacy of past mining practices, their negative environmental, social economic and political impacts, is significant.Little has been done to address legacy mine land. Current planning regimes barely address legacy mine land. Unfortunately, the South African Government has also failed to address this problem adequately.The frequently contested nature of responsibility for legacy mine land adds complexity and inertia to effective management of these areas.
Radioactivity has become an area which requires special attention because of a history of extreme secrecy and confidentiality on all nuclear issues. It has been shown that the risk posed by uranium an important by-product of gold mining within the Wonderfonteinspruit Catchment and an identified hazardous component of the wastes and effluents from gold mining activities, occurs due to both radiotoxicity and chemical toxicity with, in some cases, the chemical toxicity dominating over the radiotoxicity.
The lack of high confidence assessments should not at any stage prohibit intervention from being applied, predominantly by the regulators, but also by the industry and other stakeholders.The criteria for intervention should be predetermined so as to ensure that the safety of members of the public is not compromised by protracted interpretations of safety levels.
WATER USE LICENSES
It is of significant concern, after the effluxion of 10 years since the promulgation of the National Water Act in1998,that water use/discharge licenses have, at the time of writing not been issued.
ENVIRONMENTAL MANAGEMENT PROGRAMMES
The current status of the Environmental Management Programmes is further reason for concern - 4 amended EMP submitted, and 7 EMP outstanding.