De Beers Consolidated Mines Limited and Mvelaphanda Resources (Pty) Ltd. in a joint venture, Ndowana Exploration Two (Pty) Ltd., are prospecting for a diamond mine in the Wolkberg Mountains 4.5 km from the town of Haenertsburg
The NEMA regulations require an environmental assessment to be done for their next phase of prospecting. The regulations offer two formats for this, a “Basic Assessment” or the more onerous “Full Scoping & Environmental Impact Assessment (EIA)”. The regulations provide guidance on which format should apply to various activities but indicate that prospecting could fall into either category. The decision as to which to adopt is thus left to the environmental practitioner employed by the mining company. Once the assessment is submitted to the responsible government authority, this decision needs to be evaluated and either endorsed or rejected. This is of crucial importance in the current case.
In acknowledgement of the extremely sensitive, critically endangered and irreplaceable environmental biomes that exist in the area as well as the strong community opposition to these activities, De Beers have gone beyond what would normally be done in a “basic assessment”, yet they have failed to address the full legal requirements of a proper EIA. They contemplate four activities plus road building,
It is our contention that while a Basic Assessment would be appropriate for activities 1 & 2, activities 3 & 4, which might also require road construction in the pristine area, demand a full EIA. It appears that De Beers are trying to take short cuts in lumping activities together. They acknowledge this in saying they will do further studies when they move to activities 3 & 4. It should, however, be explicitly stated that activities 3 & 4 require a full EIA to avoid the possibility that these activities could be undertaken without such a study.
The area is an important repository of biodiversity, including ecosystem processes e.g. water catchment and carbon sequestration. The botanical specialist study concludes that the upper site is a very sensitive habitat (protea grasslands) and should be avoided i.t.o. prospecting activities rated as having a significant impact such as activities 3 & 4 (Winter 2008). The lower site includes a piece of equally sensitive Woodbush Granite Grassland. This vegetation type is critically endangered as less than 10% of this unit is still in a natural state (Mucina et al. 2006) and is the highest conservation priority in Limpopo province.
A mistake made at this stage will not easily be remedied. The botanical specialist study highlights this “An important factor when considering mitigation of impact by rehabilitation of disturbed grassland in this area is that it is impossible to restore to its original state within human time frames once the soil has been disturbed over more than a few m2”(Winter 2008).
The approval of the Ndowana project would set a precedent for more prospecting in other non-protected areas of indigenous vegetation in the Woodbush-Wolkberg area in future. Furthermore, once prospecting has already taken place in this area, the vegetation will be seen as “already compromised” and further applications for any additional development of the area, whether for mining or any other land use, could be more favourably viewed because the land is no longer pristine. The cumulative impact of several prospecting projects will result in the degradation of the natural environment and threaten the biodiversity. The botanical specialist study calls for the conservation authorities to set a clear threshold for the amount and type of prospecting to be allowed, if any, in the Woodbush-Wolkberg area in unproclaimed areas with conservation potential (Winter 2008).
The close proximity of the site to the town of Haenertsburg has created great concern in the community. It poses a threat to the local tourism industry in which a great number of permanent tourism related jobs would be threatened if a mine is established. Despite exaggerated media reports, Ndowana have indicated that the prospecting will only create 12 to 20 temporary low skilled jobs.
There are serious unresolved questions in relation to water requirements for both the prospecting and future mining operations. The whole Letaba river system has been over allocated and is under continuous pressure just for current water requirements supplying both Tzaneen and Polokwane as well as farming irrigation. Lepelle Water currently extracts 159% of their allocation from Ebenezer Dam on a continuous basis. De Beers have obtained a letter indicating Lepelle Northern could supply their requirements; however, the Letaba Water User Association was not consulted and indicated they will vigorously oppose this.
Mucina, L. & Rutherford, M.C. (eds) 2006. Strelitzia 19: The vegetation of
Winter, P.J.D. 2008. Botanical specialist study for the Basic Assessment regarding the proposed extension of prospecting operations in the Haenertsburg area.