How to tell
BAR from an EIA and a slimes dam
from a wet plant
The main objections by the Mtunzini
Conservancy and the Mtunzini
Residents Association (MRA) to the application
by Exxaro KZN Sands to mine at Fairbreeze, south of
Mtunzini, is that the authorisation process has been
fundamentally flawed. It ignored Mtunzini residents'
interests and gave Exxaro an unfair advantage.
Because some authorisations to mine in the area had
already been granted, Exxaro was a permitted to only
submit a Basic Assessment Report to get authorisation
to mine as close as 100 metres from the town.
To understand the complex nature of this debate, there
are some essential definitions which need to be sorted
A Basic Assessment Report (BAR)
is the environmental assessment applied to activities
which are generally regarded as smaller scale,
the impacts of which are generally known and can be
easily managed. Typically, these activities are considered
less likely to have a significant impact on the environment.
BAR is a more concise analysis
of the environmental impacts of the proposed activity
(ie. Exxaro's planned mining) than a Scoping
and Environmental Impact Assessment (S&EIA).
A BAR still requires public notice
and participation, consideration of the potential
environmental impacts of the mining, an assessment
of possible mitigation measures and an assessment
of whether there are any significant issues or impacts
that might require further investigation.
The BAR must provide the Competent
Authority - the provincial Department of Agriculture,
Environmental Affairs and Rural Development (DAEARD)
in this case - with enough information to consider
the application to mine and to reach a decision. If
the DAEARD is unable to decide based on a BAR
alone, it may request Exxaro to subject the proposed
mining to the more thorough Scoping
requires a thorough environmental assessment
for activities likely to have significant impacts
that cannot be easily predicted. These are regarded
as higher risk activities that are associated with
potentially higher levels of pollution, waste and
A Scoping Report (including
Plan of Study) requires a description of the proposed
mining activity and any feasible and reasonable alternatives,
a description of the property and the environment
that may be affected and the manner in which the biological,
social, economic and cultural aspects of the environment
may be impacted upon by the proposed activity; description
of environmental issues and potential impacts, including
cumulative impacts that have been identified, and
details of the public participation process undertaken.
In addition, a Scoping Report must contain a roadmap
for an EIA, referred to as the Plan
of Study for the EIA, specifying the methodology
to be used to assess the potential impacts, and the
specialists or specialist reports that will be necessary.
Applicant may only conduct an EIA
after the Competent Authority has approved the Scoping
Report and the Plan of Study for the EIA.
The Scoping and EIA Process culminates in the development
and submission of the Environmental Impact Assessment
Report and the Draft Environmental Management
Plan (EMP) to the Competent
Slimes Dams, also euphemistally known
as residue storage facilities, are the dumps for the
fine waste material left over after the process of
separating the valuable minerals from the orebody.
This slurry is dumped in the slimes dams to dry out
and it becomes a permanent part of the landscape long
after the mining operation has moved on.
Rehabilitation is the process of restoring
the mined land to a predefined and agreed condition.
At Fairbreeze this will mean returning the land to
agricultural (Eucalyptus and sugarcane plantations)
Reconstituted soil, also known as
chocolate sauce, is a remix of the coarse sand and
slimes into a 70:30 ratio. The current rehabilitation
plan for Fairbreeze requires a layer 1.8m deep of
reconstituted soil to be placed, much like chocolate
icing on a cake, over the coarse sand placed in the
mine void. It is optimistically hoped that this reconstituted
soil will provide a suitable growth medium for future
agricultural production. To date the optimism appears
proposed mining of the area south of Mtunzini
has been on the cards for more than 13 years.
It was initiated by a company then known as
Iscor Heavy Minerals, which later joined forces
with an Australian company to become Ticor SA
(PTY) Ltd. It then transformed into Exxaro KZN
Sands. The latest
reports are that it is to once more metamorphose
into a new company, this time with US interests
and is to be known as New Tronox.
The proposed area to be mined is vast. About
four times bigger than the present mine at hillendale,
outside Felixton, the Fairbreeze mine begins
only 100 metres from the southern boundary of
Mtunzini and extends 13 kms south westerly -
mostly in the area between the railway line
and the N2 Toll Road. It will change the environmment
around Mtunzini forever and the gateway to this
gem of the Zululand coast will be permanent
slimes dams on the inland side of the N2 and
a ravaged, red lunar-like landscape on the coastal
unspoilt eco-tourism hub to dusty, mining town in
MINING WILL CHANGE MTUNZINI
tourism brochures boast about its 'pristine coastline'
and 'zig-zagging rivers and streams' in a 'clean and
safe environment'. They also mention its commitment
to the 'preservation of its natural heritage'. But if
mining giant Exxaro KZN Sands gets its way, all this
could be lost for future generations who may well wonder
how a village like Mtunzini and its ravaged, dusty surroundings
was ever known as the Jewel of the Zululand coast.
is due to start mining the 4 000-hectare Fairbreeze
site in 2013 - once mining at Hillendale, near Felixton,
is complete and the facilities currently being used
at Hillendale are moved to a site near Highfield
The minerals to be mined include titanium, ilmenite
and zircon, with the richest deposits found in Fairbreeze
C Extension adjacent the Xaxaza
Leisure Park at the end of Mimosa Street where
Exxaro hopes to start mining.
All Hillendale staff will transfer to Fairbreeze
and no new permanent jobs will be created. Exxaro
anticipates that just over 1 000 temporary jobs
will be created in the construction phase –
mostly when the plant is physically lifted off the
Hillendale site and moved along the N2 (the bridges
will be lifted to allow the plant to pass underneath)
to Fairbreeze and later when the plant is enlarged.
Once Exxaro gets the go-ahead to mine, the present
vegetation on the mine site will be bulldozed and
burnt, exposing large areas of soil which will then
be broken down by a high-powered hydraulic process
requiring 48million litres of water a day running
24 hours a day.
The minerals are then extracted from this slurry
and the waste pumped to two slimes dams about 5kms
away on the inland side of the N2.
the main concerns of the Mtunzini
Conservancy and the Mtunzini
Residents Association (MRA) who are opposing the
mining is that these mega-dumps, as they are also
known, are not only enormous (600 hectares in size,
5 kms long and 1,4 kms wide) but are sited on environmentally
sensitive wetlands, and will never be able to be rehabilitated.
These dumps will become a permanent eyesore at the
entrance to Mtunzini.
is nothing to
suggest that Exxaro
to do anything at
To understand the size of these slimes dams, you have
to imagine 17 golf courses the size of Mtunzini Country
Club placed side by side. “There is no evidence
in the Basic Assessment Report (BAR), or elsewhere
that we know of, to support the claim by Exxaro that
such slimes dams can be successfully rehabilitated
to economic timber production – or any other
crop,’ said a spokesperson for SOS (Save Our
Sands) which represents the interests of the Conservancy
and the MRA.
“It appears that the slimes dams could be a
threat to safety, and blot our landscape forever.
A literature search indicates that 30m high dam walls
are at the upper safe limit for slimes dams. The planned
Fairbreeze slimes dams will be 37m high in places.
"There is also no evidence to support the claim
by Exxaro that the soil hydraulically shattered by
the process can be ‘reconstituted’ and
returned to the highly productive agriculture and
forestry that is currently in place.
“Exxaro claims that the existing Hillendale
mine operation is supposed to provide all the answers
with respect to rehabilitation of the mined area and
the slimes dams and that lessons learned at Hillendale
will be applied at the proposed Fairbreeze mine.
“From our perspective, there is nothing to suggest
that they have learned how to do anything at Hillendale.
From recent visits to Hillendale, Google Earth images,
and several aerial surveys there is scant evidence
of successful rehabilitation work that has been completed
and reported on and/or published in reputable journals.”
“If Exxaro doesn’t get this right, we
could be left with a wasteland,” says Jim Chedzey
who leads the SOS campaign.
Not only a wasteland but a town which has lost its
allure and with little chance of future investment.
According to the municipal valuation roll, the village
of Mtunzini represents an investment of R1-billion
with an annual rates base of R12-million.
In contrast, Exxaro is expected to make R1,2-billion
profit annually in the 12 years that it will mine at
Fairbreeze and is expected to pay uMlalazi Municipality
only R1,6m in annual rates.
Since King Cetshwayo’s white chief, John
Dunn, discovered its charms in the 19th Century,
Mtunzini has always been an attractive place to live
or holiday in one of its many guest houses.
it is just a hop off the N2 with easy access to Richards
Bay, the famous game reserves of Zululand, King Shaka
International Airport and Durban. It’s the kind
of village where one will meet a zebra at the pedestrian
crossing or a Woollynecked Stork at the stop street.
understand the size
of the slimes dams,
you have to imagine
17 golf courses the size of Mtunzini Country
Club placed side by side
It has a history of respecting its environment and sense
In the 1940s the local civic authority handed over large
portions of the coastal forest to the Natal Parks Board
as it was concerned about the high level of poaching
A decade later Ian Garland moved to a neighbouring farm
where he pioneered stream rehabilitation and started
the first environmental education centre in South Africa.
By the millennium, Mtunzini had become the first urban
area to be granted conservancy status and it had received
many accolades and conservation awards for its work
in the clearing of alien invasive plants.
Its residents are fiercely protective of its eco-estate
lifestyle and have fought many hard battles to keep
it that way but the proposed mining is without a doubt
its biggest challenge - taking up many voluntary hours
of research, meetings, canvassing and fund-raising to
cover legal fees.
But for residents the stakes are high. Property owners
have been offered naught for their comfort - only the
fear that their life savings will drop and devalue as
Mtunzini becomes a less than attractive place to live
or visit. At present, there are more than 100 houses
on the market.
Residents are mostly concerned about the fine dust which
will blow from an open-cast mine 100 metres away, as
well as the noise levels of a 24-hour a day, seven days
a week operation.
They are also concerned about their water supply and
The mine will use more water in a day than the town
uses in a month. Who can predict how this will affect
this already critical resource, 10 years down the road?
One of the toxic slimes dams is situated in the catchment
of the Siyaya River which flows into the Umlalazi
Nature Reserve, another dam falls within the catchment
of the Nyezane River which flows into another protected
area, the Amatikulu Nature Reserve.
to mention, the main drainage lines on the Fairbreeze
site which flow directly into the wetlands behind the
sand dunes in the Siyaya Coastal Park.
an environmental education centre on the edge
of a mine is a bizarre and abhorrent mental
The shock troops of this total onslaught on the town,
are the residents of Xaxaza
Leisure Park - a small community of 65 retired pensioners
who will bear the worst brunt of the mining.
This quiet, shady warren of narrow lanes lined with
modest cabins and a popular caravan park only has a
100-metre barrier of nine-year-old trees between it
and one of the dirtiest mining operations seen on the
South African coast.
“It’s absolutely dreadful,” says Xaxaza
co-owner Merle Muller about
prospect of mining right opposite her entrance.
“I spoke to the owner of Harbour Lights [a caravan
park on the Hillendale site] and he said: ‘Merle,
the day they start mining you may as well close your
business because no one is going to stay at your caravan
park and the permanent residents certainly won’t
want to live under those conditions.
“He said it was so dirty and dusty that residents
had to wash everything every day if it had been left
outside. We all wrote letters to Exxaro and the Minister
begging them to move the mine a safe distance away from
us. I posted 65 letters but it seems to have been a
waste of time because we haven’t received a single
reply. Not even an acknowledgement from Exxaro. And
what's it going to do to our health? We’re all
Also of huge concern is the future of the Twinstreams
Environmental Education Centre situated just above
the confluence of the Siyaya and Amanzimnyama streams.
Begun 60 years ago by sugarcane farmer, the late Ian
Garland, who foresaw the threat faced by the environment
long before the present debate on climate change, Twinstreams
is now run jointly by the Wildlife and Environment Society
of South Africa (WESSA) and Mondi (the present owners
of the land to be mined).
year, more than 4 000 school children pass through the
Centre where they have the chance to explore several
pristine, diverse ecosystems, study riverine rehabilitation,
the impact of humans on catchments as well as enjoy
fun activities such as hiking along the beach and canoeing
in the estuary. Because of Ian Garland’s proud
legacy, Twinstreams has always been a valuable lesson
to all who pass through it that individuals can make
a vital difference.
was told that the day they start to mine that
I may as well close my business. No one
wants to live under
But to many, having an environmental education centre
on the edge of a mine is a bizarre and abhorrent mental
In its answer to the concerns raised about the future
of Twinstreams Centre, the Addendum Report noted only
that Exxaro ‘should financially assist with investigating
suitable alternative sites’.
In his lifetime, Ian Garland estimated that he had planted
over 60 000 indigenous trees – not only on his
own farm but along most of the watercourses on the Fairbreeze
site and wherever he felt the landscape needed a bit
of ‘cheering up’.
Mtunzini’s sense of place owes much to his voluntary
tree-planting, enthusiastic guidance, first-hand knowledge
At his funeral in 2007, all the tributes referred to
his life’s work of creating a forest along the
Siyaya as his living monument.
Who knows how this monument will look in 2020 if the
mining goes ahead?
"Many of us learnt some valuable life lessons from
Ian Garland and we saw what a lonely battle he fought
most of his life to try and save the Siyaya catchment,"
says longtime resident and farmer Bruce Hopwood.
"It's painful for us to be in the Fairbreeze area
and ponder the future of his extraordinary legacy. He
only wanted to leave the world a better place than he
found it and now we're faced with its plunder by a faceless
multi-national company that only sees profits and will
never know what we have lost."
to be generated
by Fairbreeze mine
rates to be paid by Exxaro
to uMlalazi Municipality
rates paid by
number of new permanent jobs created by the mine
WILL MTUNZINI LOOK AFTER THE
MINING HAS ARRIVED?
asked one of our resident digital artists to give
us an impression of what Mtunzini will look like once
Exxaro starts to mine at Fairbreeze C Extension which
adjoins the village. 'That will be easy', he said.
'We already know how it will look. You just need to
drive 20kms and look at how Hillendale looks today.'
call for a full Environmental Impact Assessment
is 'totally inadequate'
Conservancy chair-person Barbara Chedzey with some of the
documentation she has had to review on the mine. |
documentation on which the decision to mine at Fairbreeze
will be based has been slammed as ‘highly inadequate’,
‘scientifically unsound’ and filled with
gaps and inconsistencies, according to a group of environmentalists
monitoring the process.
Because Exxaro originally obtained authorisation to
mine in the Fairbreeze area in 1990s, it was allowed
to apply on the basis of a Basic Assessment Report (BAR)
when it applied later to mine more land - including
the contentious Fairbreeze C Extension area which adjoins
directly onto the town of Mtunzini. This short cut was
permitted In spite of the project quadrupling in size
from the time the first authorisation for mining was
sought in the 1990s.
The BAR requires less scrutiny and while having substantial
financial benefits for Exxaro, it severely prejudiced
the rights of Mtunzini residents who are demanding a
Scoping Report and full Environmental Impact Assessment.
‘Now that the full extent of mining is emerging
and we have a better picture of Exxaro’s intentions
in the area, it’s clear that Fairbreeze falls
slap bang in the middle of criteria requiring a full
EIA,’ said Julie Stacey, a specialist advisor
to the Mtunzini Conservancy and former sustainable development
operations manager (Global) for Anglo American.
Errors, inconsistencies and uncertain statements in
the documentation made ‘a good-governance decision
on the mine impossible’.
Ms Stacey said she had spent 72 hours reviewing the
documentation and found it contained conflicting information,
duplication and erroneous cross-references .
‘‘The crucial environmental management plan
Appendix F but there is no Appendix F,’ shrugged
'The BAR is an inadequate basis for a decision regarding
the levels of complexity, fragmentation, uncertainty
and the likely significance of impacts that will result
from the proposed Fairbreeze operation,’ concluded
Ms Stacey, ‘and the Department of Agriculture,
Environmental Affairs and Rural Development would be
justified in retracting its original decision given
this new information.’
Ms Stacey was attending a Media Day organised jointly
by the Mtunzini Conservancy and the Mtunzini Residents
Association during which WESSA presented their findings
on the mining.