GCS/ Mazizi Msutu

ADDITIONAL CONCERNS RAISED RE DSR/ XOLOBENI MINING’

Dear Ayanda/ Trudy

Please could you table these additional concerns of Sustaining the Wild Coast for the DSR

In no particular order of importance.

That:-

• under the current ‘climate’ and circumstances of tension and mistrust along WC it is impossible for anyone to come to an informed and objective opinion of what is best for the region, let alone for affected communties to do so.

• there seems more than enough probability that a small group of people are manipulating events/ issues to make it appear that there is far more popular support for the mining than is actually the case.

• unless a concerted effort is made to put the mining into context, both within the international significance of the PCE as a hotspot of endemism and SA ’s ratification of various international treaties to conserve biodiversity, and within other regional development options and proposals such as the WCCSDP, and that unless the benefits of mining are weighed against these, and unless the public are made aware of all these, there can be no objective decision made about the economic or social benefits of the mining or possible impacts of the mining in the region by members of the public.

• that unless affected communities are informed about the above, and about all potential consequences of the mining, they cannot make properly informed decisions.

• that language and other information used in various public presentations that I attended could be construed to be misleading and not impartial.

• that lack of putting the mining into context in terms of the significance of PCE in public presentations was an oversight that could compromise publics ability to make informed decisions.

• that there are serious questions that need to be asked about Xolco shareholding and supposed benefits that will accrue to communities as a result of the mining. e.g. will Xolco have shares in the smelter? ( which is also why smelter should not be excluded in current EIA process for unless it is included, effects and community benefits of mining cannot properly be anticipated or weighed against other options)

• that MRC appear to be trying to exclude as many of the secondary impacts as possible, e.g. smelter, roads, transport dams, from the EIA process in order to give the mine a smaller environmental impact than will be the actual case and that as far as SWC are concerned this is not legitimate nor legal in terms of best practice of the law.

• that to exclude the smelter from the EIA is a serious omission and legally questionable, given that the smelter is a direct secondary consequence of the mining and that it will have possible major economic, social and environmental impacts and will possibly affect the economic feasibility of the mining.

• that the time frames given by DME in the process are totally unrealistic and unworkable and will not in any way allow any of the issues to be given the due and weighty consideration that they deserve.

• that environmental impacts or effects cannot be considered in isolation but that cumulative effects need to be determined, and that interdependence of systems have to be understood to gain a true perspective of any impacts of mining (including effects to communities of loss or altered use of use of ‘commons’)

• that is it ludicrous to expect the public to comment or express concerns or informed opinions prior to an EIA being done into environmental impacts of mining, and that a public participation process post EIA should also be undertaken to inform public of EIA findings, and then ask for additional public input, revision of comments etc before any decision is made.

• that there are a whole host of issues relating to secondary impacts e.g. power supply, that are exceedingly vague and that affect the publics ability to make properly informed decisions or comments.

Regards

Val Payn
Sustaining the Wild Coast
P.O. Box 44
Harding 4680
Tel 0394331494
Cell 0834416961
valpayn@gmail.com

Posted on June 25th, 2007
Filed under: Letters