Responding to proposed mining plans in the upper Blyde and upper Sabie River catchments

During the last couple of weeks many people have heard of the proposed mining plans in the upper Blyde River and upper Sabie River catchments, and many have formally registered as interested and affected parties (I&APs) and submitted comments and objections.

While the 4 December deadline for comments or objections was for the draft Environmental Impact Assessment (EIA) reports and Environmental Management Programme report, we have been hearing that people (who registered as interested and affected parties and objected) have been asked by the public participation consultants, via email and letters subsequently, to review the EIA documentation and then to comment/object again.

While this in and of itself is a step in the right direction, AWARD believes that the public participation process as a whole remains completely flawed. Asking people to read and comment on these EIA documents only does not constitute a full participation process.  

We urge people to demand that it should be reopened in its entirety.

This would mean, among other things, holding public open days and convening specific meetings in potentially affected areas that have not been consulted, to explain to people what exactly the proposed mining plans are, allow people to ask questions, and note their concerns, before moving onto asking for comments on the draft EIA documentation.

Below are details ito how the public participation and EIA process should be conducted and what your rights are.

What are your rights?

The undertaking of a public participation process and public consultation in general, is a legal requirement and forms part of an Environmental Impact Assessment process. It is required that the public be informed about a proposed project in a number of ways. Any party who has an interest in or is affected by the proposed project should be invited to actively participate in the process. This means explaining to such stakeholders what the plans are, answering their questions, and noting their concerns, which should then be considered under the specialist studies conducted under the EIA process. Stakeholders should be kept up to date with any developments surrounding the project. The stakeholders should also be able to see how their inputs were integrated in the project. The comments from interested and affected parties should also form part of the Environmental Impact Assessment documents and process overview to be submitted to the government authorities.

This is according to the applicant’s own process documentation.

It is AWARD’s position that many potentially affected people and organizations, whether private, civil or government entities, have been largely denied being part of the whole of the scoping phase, and the majority of EIA phase of this process.

What can you do?

Email the public participation consultants with demands to restart the entire public participation process (whether you have already registered as an interested and affected party (I&APs) or not). You are welcome to phone them as well, but your communication and concerns are best captured in writing so that it remains on record. People who have not registered as I&APs yet should also demand to be registered as such and be allowed to be part of the public participation process. 

The email addresses of the consultants, Ingrid Snyman and Ferdi Pieterse, are: ingrid@bathoearth.co.za & ferdi@globesight.co.za . Please also cc the Department of Mineral Resources official, Ms Mashudu Mutengwe, handling the two mining right applications at: Mashudu.Mutengwe@dmr.gov.za

All people, whether registered as I&APs already (who received the mentioned response letter from the public participation consultants) or currently unregistered, should further demand to know:

  1. Considering the need for an adequate public participation process and the thousands of pages of documents under the EIA reports requiring reading what the new timeframe for the whole process would be, including for comments and objections to the EIA reports.  
  2. Then, if one is not a specialist in the environmental field, or in any of the many fields covered by the different studies, one also has the right to demand that the consultants engage with the public in areas not consulted until now to explain what these studies say (along with fully explaining the proposed mining plans).
  3. People should also be informed of what is going on with regard to the overall process, including whether important government stakeholders and other interest groups or entities which represent various interests of the public (such as district and local municipalities, water users associations, water boards and service providers, conservation authorities, etc.) who have not been consulted up to now, have been contacted and brought into the process.
  4. Environmental specialists can also demand a site visit to the proposed areas to be affected.

The email addresses of the consultants, Ingrid Snyman and Ferdi Pieterse, are: ingrid@bathoearth.co.za & ferdi@globesight.co.za . Please also cc the Department of Mineral Resources official, Ms Mashudu Mutengwe, handling the two mining right applications at: Mashudu.Mutengwe@dmr.gov.za

In all communication be sure to indicate that it is in relation to the two mining right applications, projects 10167 and 10161.

What else can people do?

In addition to the above people are also encouraged to pass this information on to other interested or affected people, who should also be encouraged to join this process.

What is AWARD doing?

AWARD and partners are in the process of establishing a broad coalition around a collective campaign to oppose the projects, and are currently considering further avenues of support and pressure, such as via the media to raise awareness around this at a larger scale.

We will also share a more detailed overview of concerns on potential impacts and aspects that need consideration following the previous brief background document circulated by email.

If you have specific questions, please email them to: publicinterest@award.org.za.