The road to sustainable development in South Africa is complex and often difficult, and is further exacerbated by human activities such as extractive mining, a key contributor to climate change. ANGUS BURNS of the World Wide Fund for Nature South Africa looks at some of the key issues
Despite South Africa having some of the best environmental legislation in the world, mining is still associated with serious negative environmental degradation and pollution.

These devastating impacts on our landscapes come not only from deficiencies in mining legislation, but also through the interpretation and application of existing legislation. Although South Africa is a signatory to many important international convention (such as the United Nations Framework Convention on Climate Change), the country is still heavily dependent on coal and the rate of coal mining is showing no signs of slowing down.
According to the Department of Energy, 77% of South Africa’s energy needs are derived from coal and that this situation is unlikely to change significantly in the next two decades owing to the lack of suitable alternatives to coal as an energy source. Yet, most of South Africa’s strategic water source areas – as well as coal deposits – are found in the high-altitude moist grasslands of KwaZulu-Natal, Mpumalanga and the Free State. This sets up an immediate conflict between coal mining and the country’s water supply. Currently, almost a third of the 1.6 million hectare WWF-SA Enkangala Grasslands project domain is subject to mining applications yet, on biodiversity alone, the wider grasslands biome is home to over 4000 plant species,15 of South Africa’s 34 endemic mammals and 10 of our 14 globally threatened bird species.

Grasslands, which cover a third of our country, are also vital for crop food production, foraging for livestock and game farming, and tourism and recreation amongst other things. Most importantly, the Enkangala Grasslands are a critical water source area, giving rise to the Vaal, Thukela and Pongola rivers. Unless we are able to strategically secure these vital water source areas and limit the encroachment of mining and prospecting activities, the path to sustainable development may well be out of reach. Thus, the extraction of mineral resources in a sustainable manner brings us to the critically important role of environmental assessment practitioners in the mining sector. EAPs are there to guide applicants and mining companies through the application processes, advising of risks to the applicant while highlighting risks to the environment, raising concerns to relevant authorities and ensuring compliance with law and best practice biodiversity information.

It is the responsibility of the EAP to deliver robust and objective environmental impact assessments and resultant environmental management plans  that ensure responsible mining and adequate mine closure and land rehabilitation. During the 2012 Budget Speech for the Department of Mineral Resources to the National Assembly, the then minister Susan Shabangu spoke of the need to streamline licensing processes to ensure compliance by right holders with the various pieces of legislation, create certainty in the regulatory framework, expedite the licensing process and ultimately strengthen the constitutional imperative of security of tenure. An important stride towards the promotion of responsible mining was the May 2013 launch of the Mining and Biodiversity Guideline for use by EAPs when conducting environmental assessments. It was jointly endorsed and released by the Department of Mineral Resources together with Department of Environmental Affairs. While the guidelines hold no legal standing, they provide pointers to existing biodiversity information and tools and how they can be used to integrate biodiversity considerations at every stage of the mining lifecycle.

In late 2011, WWF South Africa released a report titled Coal and Water Futures in South Africa: a case for conserving headwaters in the Enkangala Grasslands. The report called on government to mitigate, manage and monitor the impacts of the mining sector in order to protect our valuable water resources. It stated that sustainable economic development, water and food security required intervention at the highest levels to determine where coal mining, water and food provisioning needed to be prioritised Some of the findings included high levels of variation with regard to the quality of environmental management plans as well as qualifications and experience of the environmental assessment practitioners responsible for the compilation of these vital EMPs. The report said EAPs should be held responsible for the quality of their work, highlighting the need for peer review by external sources or completion of the EMP by external experts. 

Neverthelelss, WWF-SA’s lastest study on this topic, Mining and Biodiversity: Evaluating EAP standards in the sector, which was released this week (September 3), shows “alarmingly high levels of non-adherence” to the government’s Mining and Biodiversity Guidelines. One of the concerns raised by WWF at the outset of the development of the biodiversity guidelines was that, although a useful tool, it would not enjoy optimal implementation unless adopted as policy by decision-makers. Adoption as policy even at a regional level would go a long way to ensuring better uptake, implementation and overall mainstreaming.

If EAPs were adequately considering the relevant spatial data at their disposal, the question is raised as to why mining and prospecting applications within sensitive water production and biologically diverse areas are still being pursued at their current rate?
Angus Burn is Programme Manager: WWF-SA  Grasslands Programme.