ICWA considers Ibutho Coal’s announcement, on 18 November 2015, to delay the Fuleni EIA process in order to undertake “additional work” as both a clear admission and confirmation that the public participation process (PPP) conducted by Naledi Consulting and the draft Environmental Impact Report (EIR) prepared by Jacana Environmentals are grossly inadequate.
We stand firm in our resolve to oppose the Fuleni coal mine that will:
destroy the historic iMfolozi Wilderness area;
entail the relocation of thousands of community residents, some for the second time in living memory;
devastate the ‘Sense of Place’ of the entire Hluhluwe-iMfolozi Park;
contribute to an increase in rhino poaching as well as other wildlife and associated crime; and
sabotage new eco-tourism and agricultural projects that bring sustainable development to the area and contribute to the livelihoods of thousands of people, while the mine offers at most 200 non-permanent jobs to local residents.
The three inconsequential interventions proposed by Ibutho Coal and the consultants to address the serious inadequacies identified in the draft EIR and the process to date, fail to consider two fatal flaws:
Lack of water and,
The current global fossil fuel divestment campaign that has seen coal mines closing worldwide and coal shares plummeting with little likelihood of recovery.
LACK OF WATER
Zululand is experiencing a serious drought. This is a long-standing pattern in the area, where droughts often last more than ten years followed by dramatic flooding, like the Damoina floods of 1984.
Predictions for Zululand are that climate change will exacerbate the existing regimen, with droughts and floods becoming more severe. Both scenarios spell disaster for mining. Mines are thirsty and without sufficient water during the dry periods, a mine cannot operate without seriously impacting on other water users, including downstream communities, tourism operations, farmers, wildlife and livestock.
During periods of flooding, pollution from the mines, especially open cast coal mines, will inevitably be washed into groundwater and riverine systems and contaminate vitally important water sources. Consider the Mfolozi River that culminates in the sensitive ecosystems of Lake St. Lucia. A major flood would inevitably damage South Africa’s first World Heritage site and could result in our proud World Heritage status of the iSimangaliso Wetland Park being revoked.
Some residents of Ntuthunga 1, a village directly affected by the proposed Fuleni mine, are currently restricted to 25 litres of water per week for all their needs. On 15 November, irate KwaMsane residents near Mtubatuba burnt a community hall and closed the N2 because of water shortages, sewage and electricity, problems on-going since 2014. Tourism establishments in St. Lucia village and surrounding areas are closed because there is no water for guests. The upstream Somkhele mine has been implicated in contributing to the lack of water in the area.
Wildlife in the Hluhluwe iMfolozi Park and the iSimangaliso Wetland Park are dying of hunger and thirst. Fuleni and Somkhele residents are complaining that their cattle and other livestock are dying because of the drought.
Contrast this with the Fuleni mine’s draft EIR that states the mine requires the equivalent of 56 municipal-sized swimming pools of water every day!
The draft EIR proposes to dam the Mvamanzi River, a tributary of the Mfolozi River. According to Fuleni residents, since the Somkhele mine started its operations in 2007, the once perennial Mvamanzi River has been reduced to a seasonal stream that often runs dry. At the moment it is a small trickle.
The bottom line is there is no water for the Fuleni mine. No amount of revisions to the EIA and new specialist reports will be able to fabricate the water that is required.
COAL MINING INDUSTRY
No matter how one chooses to look at it, coal mining is on the decline as global concern about the role of fossil fuels in climate change gains momentum. This is the focus of the current COP21 meeting in Paris. Worldwide there are a growing number of reports of coal mines and coal-fired power plants being shut down. This comes in the wake of the bold launch by the London Guardian of a fossil fuel divestment campaign, started in March 2015. Commodity prices are seeing a dramatic fall in value, a trend that is predicted to continue.
It is too late for Ibutho to consider pursuing their seriously flawed EIA. Their decision to now consult with the affected Fuleni communities and other Interested and Affected Parties is simply too late!
We are almost two years into the process and not one public meeting has been held to explain the project to the broader public. This serves to reinforce the mining company’s complete disdain for community opinions and exercising correct due diligence at the start of the project.
Fuleni community representatives working closely with the Global Environmental Trust (GET) are ready to challenge any impression that directly affected villages have been consulted by Ibutho Coal or its consultants about the proposed Fuleni mine.
The focus of Ibutho Coal and Jacana’s engagement has been the traditional leadership, which has created a continuing rift that has serious implications for the future cohesiveness and well-being of Fuleni, whatever the outcome of Ibutho Coal’s mining application.
The public participation process is a critical part of the scoping phase. It is intended to gather information to inform the scoping report, which is the foundation of the EIA process.
While the consultants are well aware of the public participation principles required by National Environmental Management Act (NEMA) they certainly have not implemented them.
None of these principles have been adhered to despite repeated requests from community members for:
Direct answers to their pressing questions about precisely which houses will be affected by the mine;
Where they will be moved to in the event that their houses have to be demolished to make way for the mine?
How many and what kind of jobs will be guaranteed for Fuleni residents? and
How were two prospecting licences granted without following the required legal procedures?
Instead the only documentation available in Zulu is highly technical summaries of specialist reports that most IAPs would find impossible to comprehend.
At a joint GET and groundWork meeting held on 11 June 2015 with the Department of Economic Development, Tourism and Environmental Affairs (DEDTEA), the department agreed to organise an Imbizo in Fuleni to explain the public participation process (PPP) to the affected communities. Several dates have been set, only to be postponed.
Five months later and the Fuleni communities are still waiting for the promised PPP that everyone agreed was a matter of urgency.
Instead of Ibutho Coal considering additional specialist reports, the two aspects of the EIA that urgently need to be revisited are issues relating to water and to the economic viability of the project based on accurate information relating to the distribution and value of the coal seams and taking into account the current economic climate as a result of mounting global opposition to investing in fossil fuels. The outcome should be a clear No Go in both instances if the specialists are competent, independent and truly concerned about the environment and the best options for the country as a whole, rather than trying to please the project proponents.
If the plan “to reduce the zone of influence associated with the mine” involves a change in the location of the mine, a new mining application will be required, which GET, ICWA and other Interested and Affected Parties would definitely challenge.
Anything less, would not materially reduce the impacts detailed in GET and groundWork’s 40 page submission compiled by Kirsten Youens, our legal representative, detailing major concerns about the content of the draft EIR. This submission is supported by the iMfolozi Community and Wilderness Alliance (ICWA).
We caution the public not to assume that this battle has been won. Ibutho Coal has invested many millions in this proposal and is unlikely to walk away from it without a fight. We expect the onslaught to resume in the new year and so call on all our supporters to keep up the pressure to prevent the Fuleni coal mine project from seeing the light of day. Together we can and will make a difference.
082 295 7328
Global Environmental Trust and Spokesperson for the iMfolozi Communities and Wilderness Alliance (ICWA)
c/o Ewing Trust Company
PO Box 1, Hillcrest, 3650
Mobile Tel : +27822957328