I trust you are well.
MACUA has registered as an I&AP for the proposed mine at the Fuleni community. It is based on that, that I write to pass my concerns and wish for clarity on your behalf.
It is 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 which will be affected by the change in land use. This is the purpose of the scoping phase of the process. Since a meeting with the ITB and the community has not taken place, none of the issues that affect the community have been identified. Basically the scoping process is incomplete. The proposed plan of study which is the culmination of the scoping phase therefore limits what will be assessed in the next phase. Aspects that have not been identified will not be assessed.
One of my concerns is 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 occupies of the land in writing and details the Department’s requirement for consultation. The EAP must fulfil this requirement.
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. 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. However there is evidence in the report that the Fuleni Project may be extended to other areas on the site. Nonetheless, if the MRA is 14 615 ha, all lawful occupies 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.
With these concerns, we are going to make ourselves available for the entire process as a I&AP.
Mining Affected Community United in Action Provincial Co-ordinator KwaZulu-Natal
Nothing about us without us – MACUA