Please see below the comments submitted to Chris Wright of Black Rock Environmental, by Sheila Berry on behalf of the Global Environmental Trust(GET) and the iMfolozi Communities and Wilderness Alliance(ICWA).
I am writing on behalf of the Global Environmental Trust (GET) as IAPs for the Luhlanga pit expansion, IWULA and Waste Management application. We have been in contact with some of the wilderness and conservation organisations in KZN and they have endorsed GET’s role as spokesperson forthe iMfolozi Communities and Wilderness Alliance (ICWA).
We have received MCEJO’s comments on the draft scoping report submitted by Youens Attorneys and we hereby fully support the contents of the document and the issues raised.
We await the duly amended Scoping Report and will make detailed comment then. At this stage you might want to consider some of the concerns related to the draft Scoping Report :
1. The small number of IAPs listed at the end of the document is of great concern. In addition to MCEJO members, who will be most affected by the expansion and must be included, there are organisations like the Wilderness Leadership School and the numerous tourism operators who have to travel past Tendele mine’s operations on a daily basis en route to the Hluhluwe iMfolozi Park (HiP). This is extremely negative to the tourism industry as the sense of place associated with a South African bush experience is ruined on the way to the entrance. This has to be considered in the Need and Desirability section of the report as well as the Alternatives.
2. Page 18. Reference is made to the rehabilitation plan in the approved EMP. We support MCEJO’s request for this detailed information to be part of the scoping report plus an update of the extent to which the mine has complied with the rehabilitation plan to date, and how successful it has been, according to an external evaluation.
The statement that open cast areas will be backfilled to “ensure the topography is not markedly altered (italics added) after mining” …. needs far more detail. Who determines what is markedly altered? Where are examples where backfilling has taken place at Somkhele and the topography is not obviously altered? Who has assessed the success of these attempts at rehabilitation? When?
3. Page 23. Regarding the statement that “there are already high levels of ambient noise”. The Scoping Report needs to provide detailed information about current high noise levels and their cause as well as the impact this has on the community.
4. Page 24. Reference is made to the fact that the area is very windy and there are relatively few calms. This information needs to be integrated into the blasting schedule and strict guidelines laid down regarding wind conditions and wind direction when blasting is allowed to take place, to limit the impacts from dust as much as possible.
5. Page 26. The exhumation of graves is of ongoing concern with a long, sad history. Clearly a lot more information needs to be provided and a proper plan put in place to deal with legal compliance and community concerns.
6. Page 30. Mention is made of thousands of aloes that will have to be moved. This is a valuable resource for many uses. Given approval is given for the expansion, we strongly recommend that an opportunity be given to allow harvesting of these and other valuable plants before the area is cleared. These are also protected plants. Kindly provide us with the proof that permits have been received to remove these (and other) protected plants
7. Page 32. Regarding the unemployment figure of 42.8%. This needs to be interrogated, especially in a rural farming community where there are many self-employed farmers who are considered unemployed simply because they are not part of the formal job market. Agriculture is by far the largest employment sector in South Africa.
The Scoping Report should provide information about how many self-employed farmers,who have been supporting their families sustainability for decades, have been relocated and are now truly unemployed, with no land to provide for their families and themselves?
The Scoping Report also needs to indicate how many jobs the mine anticipates will beavailable for members of families displaced off their land in Luhlanga to make way for the mine. It was clear at the PPP meeting on 26 January that many people are expecting/hoping to be employed. One man openly stated that his support for the expansion of the Luhlanga pit was conditional on his being employed. How it the mining planning to deal with issues like these?
There are also concerns that the mine is negatively impacting on tourism and that this could result in job losses.
8. Page 33. Tendele has never been able to provide evidence to substantiate its employment claims that, compared with open coal mines worldwide, are highly inflated. Until there is proof in the public domain that Tendele has 1300 employees, we strongly contest this statement. Proof needs to be given that Tendele itself (not its sub-contractors) employ 1300 people and more than 1000 of these (83%) are from the Somkhele area.
With regard to the “benefits” listed in the draft Scoping Report, it is essential to include information from Action Aid’s Audit of Tendele’s Social Labour Plan in the revised Scoping Report. Simply to present what the mine says it has provided, without any evidence to substantiate the claims, is not acceptable, especially when there is an independent report that is readily available. This indicates bias on the part of the EAP who is supposed to be independent.
9. Page 36. Regarding specialist reports, in addition to wind, blasting, dust, health, it is also important for a specialist to provide a comprehensive Needs and Desirability report that must not be focussed on the need and desirability of Tendele only.
Regarding blasting and safety, some years ago the mine unilaterally decided to stop the siren that warned residents of a blast. This is contrary to the law. For safety reasons and to lessen the impact on residents, teachers and learners at schools in the vicinity, it is essential that, at the very least, the warning siren is reinstated.
10. Page 46. Impacts Table. Air Quality. To describe dust as “a nuisance” not a health hazard displays a concerning lack of knowledge about the abundance of research on health impacts associated with coal dust and air pollution. This statement cannot stand.
11. Page 47. Regarding noise and blasting impacts, the Scoping Report needs to include a proactive plan of how the mine is going to deal with cracks in houses that will occur, given the depth of the coal seam. A ripper will reduce the cracks but blasting will undoubtedly damage and destroy houses. It is unacceptable for the mine to shrug off responsibility for this as it has done in the past. The Scoping Report must address this serious issue and suggest appropriate measure to reimburse people for damage caused to their homes and other structures as a result of blasting by the mine.
Thank you for the opportunity to comment. Hopefully the above input will assist with the revision of the Scoping Report.