BRIEF BACKGROUND DOCUMENT ON POTENTIAL IMPACTS AND REASONS FOR OBJECTION TO PROPOSED TGME MINING PROJECTS IN THE UPPER BLYDE RIVER AND UPPER SABIE RIVER CATCHMENTS

Below are some of the key concerns on which to raise objections to the proposed mining projects, and to demand a reopening of the public consultation processes. This is by no means an exhaustive list and many more reasons could be added, and we encourage you to do so. Note that developing the rationales as listed here has been a combined effort by many concerned partners, including the Kruger to Canyons Biosphere (K2C), SAFCOL, York Timbers,

Please be sure to object to both applications in ensuring a stronger collective effort.

1. The applications completely fail to consider the recently gazetted Water Resources Classification System under the National Water Act. 's National Water Act (Act 36 of 1998), replaced all previous rights to water use with an entitlement under the new Act. The NWA now only makes provision for one "right" to water, the Reserve. This is the water required for basic human needs and to maintain water ecosystem functioning. Supporting this the act also stipulates that the water resources should be classified, the ecological reserve be determined and Resource Quality Objectives (RQOs) set for all South African river systems. The classification and RQOs for the Olifants and Sabie River Catchments which were gazetted in 20161, specify that the upper Blyde and upper Sabie catchments are Class I Water Resources. This means that the catchment should be managed in a manner that protects and preserves its ecological integrity, therefore, minimal development is allowed to ensure it keeps providing ecosystem goods and services locally and downstream. There is evidence in water quality data collected by the Department of Water Affairs and Sanitation (DWS) that legacy impacts from previous mining activities are still present in the Blyde River as indicated by elevated arsenic levels. We believe that there is no way to mitigate impacts associated with mining activities in this strategic water source area, therefore any mining would certainly compromise the water quality and ecological integrity of these Class I river systems.

2. The Blyde River system is one of the last remaining tributaries which, provide a buffering service to the already water stressed and water quality compromised . This means that the water contributed by the Blyde River system dilutes (improving water quality) and augments the quantity of the water in the main stem of the Olifants River. Any activity impacting on water quality and quantity would jeopardise this buffering service of the Blyde and place the entire lower Olifants in South Africa and the Lower in Mozambique at risk.

1 Government Gazette 22 April 2016 (Notice 39943 No. 466) Classes and Resource Quality Objectives of Water Resources for the Olifants Catchment; Government Gazette 30 December 2016 (Notice. 40531 No. 1616). Classes of Water Resources and Resource Quality Objectives for the catchments of the Inkomati

Sunset Office Park, Cnr Koedoe & Buffel Sts, Hoedspruit 1380 • PO Box 1919, Hoedspruit, 1380 T +27 (0)15 793 0503 • F +27 (0)86 244 7106 • E [email protected] • W award.org.za

© 2017 The Association for Water and Rural Development • Directors: Dr Sharon Pollard, Mr Patrick Maunatlala, Mr Matthew Prior Company Reg. No. 98/003011/08 • Non-profit org. Reg. No. 006-821 3. The proposed sites, and the respective upper catchments within which these fall, fall within South Africa’s Strategic Water Source Areas further highlighting the importance of the upper Blyde and upper Sabie catchments and the water they provide to a multitude of downstream users and sectors, and the multiple benefits these provide.

4. South Africa is bound by transboundary responsibilities and agreements when it comes to its shared water basins, being positioned upstream in the transboundary basins of the Limpopo (of which the Blyde and Olifants Rivers are part) and the Inkomati (of which the Sabie River is part). As a signatory of the Southern African Development Community’s Revised Protocol on Shared Watercourses (1995) this obligates South Africa to cooperate on the management of the shared water resources and to ensure that use of these shared resources is sustainable, equitable and reasonable and shall jointly prevent, reduce and control pollution. Furthermore, in the Inkomati Water Management Area, which includes the Sabie River’s cross border flows, South Africa is bound by a treaty in the form of the Interim Inco-Maputo Agreement (IIMA, 2004). The proposed developments would jeopardise South Africa’s commitments ito the above.

5. The proposed sites overlap with multiple terrestrial and aquatic CBA and ESA areas under the Biodiversity Sector Plan (MBSP, 2014) and the National Freshwater Ecosystem Priority Areas (NFEPA, 2011). The proposed sites also overlap with three nationally listed Threatened Ecosystems (Malmani Karstlands, Northern Escarpment Dolomite Grassland, and Blyde Quartzite Grassland) in need of protection under the National Environmental Management Biodiversity Act (NEMBA, 2004). Several of the proposed sites overlap with Priority Areas under Mpumalanga Tourism & Parks Agency’s (MTPA) Protected Area (PA) Expansion Strategy. Further fragmentation of these areas in conjunction with further planned mining projects in these areas will fundamentally compromise the terrestrial and aquatic ecological integrity of these already threatened areas.

6. The proposed sites fall within the Mpumalanga Panorama route, with several major tourist attractions directly adjacent to these, including the Burke’s Luck Potholes, & Three Rondavels, God’s Window, and others, all which are of national significance in terms of the tourism sector. Tourism is a major sustainable economic activity and employer in this area, and the visual, noise and other polluting impacts of mining will have major negative impacts on this sector. Water quality impacts would also compromise downstream tourism locations and enterprises in the Lowveld. We strongly contend that mining is not an activity compatible to tourism in this landscape, and would significantly compromise this sector.

7. Reduced water quality in the Blyde and Sabie Rivers will impact the Hoedspruit and Sabie farming areas which is nearly fully dependent on water from the Blyde and Sabie Rivers for irrigation. Reduced water quality would threaten the GlobalGAP accreditation of these farming enterprises, and their access to the export markets associated with this, would could have significant financial impacts on these areas. Farming is a major economic activity in these area, with a combined annual turnover of well over 1 billion rand, and employs several thousand people seasonally and annually.

8. The upper Blyde and upper Sabie Catchments are the highest priority catchments in Mpumalanga province (and amongst the highest nationally) for the Department of Environmental Affairs’ (DEA) Natural Resource Management (NRM) Programmes

[Insert document title/other here] | 2 (through its Working for Water and associated programmes). The NRM programmes, in collaboration with other civil society and corporate partners, have made, and continue to make, investments of several hundred million rand in ecological restoration (especially alien plant clearing, and wetland and riparian restoration) and job creation in these catchments in the past 20 years, and currently provides employment for several hundred beneficiaries. The main objectives of the Working for Water programme is to improve and secure water flow and quality in the catchments in which it is working along with beneficiation of poor community members, and it is clearly evident how detrimental impacts on water quality and quantity through mining would severely undermine the ecosystem service gains, and continued security of these. Equally the proposed projects would also place at risk the continued investment and creation of sustainable employment by DEA NRM and other natural resource management agencies and funders in the upper Blyde and upper Sabie Catchments.

9. We contend that the lists of Interested & Affected Parties (I&APs) for both applications are completely inadequate, and that the consultation of I&APs processes for both applications have been completely inadequate, denying many local and downstream I&APs the opportunity to fully and properly consider these applications and their associated studies and give input into these processes. We explicitly demand a reopening of these processes and adequate extension of time to allow for proper consultation and consideration of these applications and their associated studies by I&APs.

10. There are currently multiple mining prospecting right applications, mining right applications, and granted mining rights in the upper Blyde and upper Sabie catchments which as highlighted above are critical Class 1 Water Resource Areas, SWSAs, CBAs & ESAs, PA Expansion priority areas. This requires the full cumulative and distributed impact of all these to be considered and studied on the above listed critical resources and areas in evaluating individual applications such as these.

11. For residents of the Blyde catchment (Hoedspruit, Phalaborwa, etc.) do note that the mined ore from the planned Sabie mines is to be processed at the TGME plant in Pilgrims Rest right next to the Blyde river, and pollution from this plant (which uses a cyanide based leaching process) and its associated tailings dams poses severe risks to the water quality of the Blyde.

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