Submission by the Wilderness Alliance


P. O. Box 53058

Yellowwood Park



Tel. contact no: 

Contact person: Sheila Berry

Date: 12 May 2014

To: IDM Consultants

For Attention: Karl Wiggishof

Re: Fuleni Anthracite Project, Ibutho Coal (Pty) Ltd.- DMR REFERENCE: KZN 30/5/1/2/1/10045 MR

Please register the Wilderness Alliance as an I&AP. Most of the organisations under the umbrella of the Wilderness Alliance have long-standing connections with wilderness, particularly the iMfolozi Wilderness Area, and have already registered as IAPs and submitted comments and objections to this proposal. We have now joined forces to speak with one voice on this matter. For the list of local and international organisations affiliated to the Wilderness Alliance see Annexure 1. We will keep you informed of new additions to the Alliance.

Below are our concerns and objections to the proposed Fuleni mine:

  1. The proposed development conflicts with objectives of the Hluhluwe-iMfolozi Park (HIP) and would definitely fall within a buffer zone.

  2. Though the mine is not in a protected area, the close locality of the mine (40 metres from the HIP/Wilderness Area boundary) runs counter to the growing international recognition that protected areas are No-Go Areas for mining and extractive industries because of the incalculable value of these areas and the threats posed to biodiversity and sustainability. Two important international documents to consider are: WILD10 Resolution 2013 and IUCN’s Recommendation 2.82 (2000) stating that mining should not take place in IUCN category I–IV Protected Areas.

  3. Even mining industries have committed themselves not to mine in protected areas, e.g. International Council on Mining and Metals (ICMM) in its Position Statement on Mining and Protected Areas, September 2003; available at:; and Shell’s Group Biodiversity Standard 2003; available at:

  4. Whilst 6.4% of South Africa area falls under formal protection, less than 1% is protected as wilderness. The iMfolozi Wilderness is one of SA’s oldest wilderness areas and is protected as such under section 41(2) (g) of the Protected Areas Act with direct designation under section 26 underway.

  5. The proposed mine would eliminate a nationally approved plan to extend protected areas, which is aligned with the IUCN and UN’s global strategy to move towards socio-economic and environmental sustainability through fostering important links between wild places and sustainability goals, and simultaneously contributing to improved livelihoods for communities within the area.

  6. We question and challenge the re-zoning to mining of tribal trust land designated for indeterminate use and currently being used for agriculture and grazing land use and associated with ecotourism. We also question to what extent consultation has taken place with the three municipalities affected by the Fuleni mine and question and challenge whether mining is consistent with the IDP’s of the affected municipalities.

  7. The public participation specialists have been employed to do the job of engaging with all relevant parties and the community in particular. We support MACUA’s concerns that the consultants have not complied with the requests of iNkosi Mthetwa and the Umhlana Traditional Council to meet with the community and properly explain what the project was about. Members of the community are not included in the list of registered interested and affected parties and there is no evidence in the draft Scoping Report that this community meeting has taken place.

  8. Engagement with the Ingonyama Trust Board (ITB) is not recorded. Given that one of the functions of the Board is to control “the material benefit and social well-being of the individual members of the communities and tribes living on Ingonyama land” this is considered a serious omission. Any land or real right in the land is held in trust by the Board for and on behalf of the members of tribes, communities and the residents.

  9. It is the purpose of the scoping phase and the responsibility of the Environmental Assessment Practitioner to ensure that processes have taken place to identify all the issues and concerns of the community or communities that reside on the land to be affected by the change in land use. The scoping process is incomplete because meetings with the ITB and the community have either not taken place or not been recorded and thus none of the issues that affect the community have been identified.

  10. We are also concerned about the extent of community consultation. The communities affected by the change in land use have not been identified in the draft Scoping Report. The acceptance of the application for mining rights by the Regional Manager of Mineral Resources specifies that the applicant must notify and consult with the lawful occupiers of the land in writing and details the Department’s requirement for consultation. The EAP must fulfil this requirement.

  11. The draft Scoping Report informs that the Mining Rights Area (MRA) in the application for mining rights is 14,615 ha of the farm Fuleni Reserve 14375 and consequently all lawful occupiers of land within the MRA must be consulted and the environmental impact of the mining on the entire site must be examined, as well as the impact on adjacent properties.. Although it is not clearly stated in the report, it appears that the consultant has limited the scoping process to the area where the mining infrastructure will be constructed and pits dug, despite evidence in the report that the Fuleni Project may be extended to other areas on the site.

  12. Mining is one of the greatest contributors to climate change and global warming. Current coal reserves planned for the South African market exceed the South African government’s ‘required by science’ commitments to reduce carbon dioxide emissions.1 The South African government should not be commissioning a new coal mine when all the evidence points to the country needing to stop coal mining altogether if it is to meet global targets to reduce climate change.

  13. Attention needs to be given to the direct and indirect emissions of greenhouse gases from both the proposed mining operation, as well as from the transportation and combustion of the coal/anthracite produced, whether exported and burned overseas or used locally for energy generation. Where exactly is the high quality (low sulphur content) material being export to and what are their standards for limiting greenhouse gas emissions? Similarly, with the lower quality and ‘waste’ coal; where is it likely to be exported to and what are the emission standards in these countries? It is essential that the scoping process for any new coal mining operation in SA includes at the very least a detailed assessment of its effects on the local climate, including the costs of negative impacts on health, agriculture, tourism, conservation of biodiversity, subsistence livelihoods, etc.

  14. The current block plan in relation to HiP’s boundary is between 40 and 70 m away from the boundary. The stockpiles will be 70 m high. It is an open cast mine and so there will be blasting and the resultant dust from the blasts and the gravel roads in the area. The noise intrusion into the Wilderness Area will impact on the wildlife and birdlife and spoil any sense of wilderness. Vibrations from blasting are also likely to affect the elephant population in the park. At night, the light pollution will seriously dilute the impressive night sky. This is likely to impact on the number of trailists booking for wilderness trails.

  15. To assess the true value of the iMfolozi Wilderness Area, in addition to costing the benefits derived from ecosystem services over the years of HiP’s existence, it is also important to assess the value of the “sense of place” and the psychological/ therapeutic benefits derived from the iMfolozi Wilderness Area for the more than 100 000 people who have experienced a wilderness trail since 1958. A calculation would also be required for the value of projected future psychological and therapeutic benefits derived from the iMfolozi Wilderness Area taking into account the escalating value of wilderness as a result of its increasing scarcity. It is important to note in this regard that wilderness trails have played a significant role in transforming the lives of many people who have gone on to achieve leadership positions, as well as contributing to the rehabilitation of Youth At Risk, convicted criminals and in reconciliation processes between warring factions, eg. The IRA and the Protestants in Ireland.

  16. Comprehensive information is required regarding sources of water and diversions of water courses to supply the needs of the mine. Direct and indirect impacts on wetlands, streams and rivers in the catchment need to be assessed as well as risks of altered flow, siltation and contamination of water, including controlled and uncontrolled discharges from the mine finding their way into the system. The impacts on the iSimangaliso Wetland Park and World Heritage site need to be assessed and quantified in final terms.

  17. The spread of alien vegetation into the Wilderness Area of HIP as a result of disturbance from the mine is also of concern given the difficulty and costs of eradicating or managing aliens in such a sensitive area. Who is going to bear these costs?

  18. Engagement with the local community seems to have been superficially addressed with community members not being adequately informed of all the socio-economic ramifications. Substantive evidence needs to be provided to back the statement that Fuleni mine will indeed provide 200 jobs, before it is presented as one of the benefits of the mine. During the planning, scoping and EIA phases, most proposed mines promise more jobs than is actually realised when the mine becomes operational. The more skilled jobs tend to be reserved for non-local residents. Where will these non-local residents be accommodated? How fully have these likely scenarios has been adequately explained and communicated to the Fuleni communities?

  19. What are the long-term plans for decommissioning the mine? It is likely to be disastrous for HiP if a large group of people living right on the boundary of the Park/Wilderness Area are without employment and the only thing that separates them from a source of food lies is a game fence.

  20. A growing body of research shows that, in the longer term, far from improving livelihoods and creating jobs, mining creates few jobs, for a few people, for a few years (20 years); but ultimately mining leads to a loss of livelihoods. Nationwide, while there has been a 59% increase in the number of operating mines, employment generated by mines has only increased by 15%, or approximately 118 new jobs per new mine.2 A World Bank study showed that African countries whose economies were based on mining failed to reduce poverty significantly and that the ‘benefits’ from mining do not reach the poor.3

  21. Throughout SA, local farmers report destruction of livelihoods by mines, particularly coal mines. The social and environmental impacts of mining activities have been shown to be so severe4 that mining can reduce agricultural productivity by 40% for 20km around the mine.5

  22. Mining can also cause ill-health and deaths of mine workers and a mine often foments unrest and disrupts the fabric of local communities. There is no indication of how Ibutho plans to engage with these health, security and social issues.

  23. Similar developments on the boundary of the iMfolozi Wilderness Area have been associated with an increase in criminal activity within the communities and also impacting on HIP. The Hluhluwe-iMfolozi Park retains a critical role in rhino conservation by providing a refuge for the densest concentration of rhino in the world. The HIP is already under serious threat and any further dangers to its rhino population, a national and world heritage beyond price, should not even be contemplated.

  24. There is evidence of Stone Age settlements in the area and it has been sacred to the Zulu people since the time of Shaka. The iMfolozi Wilderness Area was the first wilderness area declared in Africa, in 1958, and it is situated in the historic Hluhluwe-iMfolozi-Park, the oldest protected area in Africa, proclaimed in 1895. Since the Wilderness Area was opened to the public in 1959, it has become sacred for many thousands of local and international visitors who have been on trail. The iMfolozi Wilderness Area needs to be respected and held sacred for current and future generations. It is vitally important to preserve the integrity of an area that is steeped in South Africa’s history, and in no way should the Wilderness Area be compromised.

Thank you for recording these comments and objections to the Fuleni Anthracite Project. We reserve the right to add to these comments and objections as more information emerges.

The Wilderness Alliance

Annexure 1: The Wilderness Alliance

Local organisations affiliated to the Wilderness Alliance:

Wilderness Foundation – SA

Global Environmental Trust

Wilderness Action Group

Wilderness Leadership School

African Conservation Trust

Magqubu Ntombela Memorial Foundation

Game Rangers Association of Africa

Project Rhino KZN

Makhado Action Group

Mining Affected Communities United in Action

South African Trust for Protected Areas

Umbhotshoselwa Wezaqueque Organisation

International organisations affiliated to the Wilderness Alliance:

The Gaia Foundation


Wilderness Specialist Group of IUCNI


World Wilderness Congress

Wilderness Conservancy – CA, USA

1 See: Unburnable Carbon: Budgeting carbon in South Africa Carbon Tracker, November 2012.

  1. 2 Analysis of figures quoted by the Minister for Mineral Resources Susan Shabangu, in her recent Budget Vote Speech to Parliament, “the number of operating mines [in South Africa] has increased from 993 in 2004 to 1579 in 2012”. In the same period, “employment grew from approximately 448 909 in 2004 to 518 240 in 2012”.

3 See: Mark Tran, Africa’s mineral wealth hardly denting poverty levels, says World Bank, The Guardian, 5 October 2012.

4 BFAP, Evaluating the impact of coal mining on agriculture in the Delmas, Ogies and Leandra districts – With a Specific focus on maize production (2012).

5 See: Fernando M. Aragon and Juan Pablo Rud (2012) Mining, Pollution and Agricultural Productivity: Evidence from Ghana


Please sign our petition and say NO to the Fuleni Anthracite project.

Take a look at our Action page to see what else you may do.

Leave a Reply

Your email address will not be published. Required fields are marked *