Lots of apparent irregularities around the Elandsfontein phosphate mine?

13 October 2015

Elandsfontein looking west towards the lagoon (Carika van Zyl)

Elandsfontein, looking west towards the lagoon (Carika van Zyl)

The goings-on around the approval of mining rights for the proposed phosphate mine on the South African west coast at Elandsfontein (in the buffer zone of the West Coast National Park no less!), seem a tad murky.  There seem to be a slew of procedural anomalies and some of the specialist work, for a project that could, potentially, have ecological implications that extend into the marine environment, appears somewhat superficial – with concerns raised on review.  Political interference in favour of the mining has been alleged.  Legal opinion shows that the mining company may have been ill-advised in terms of their procedural obligations to seek approval under NEMA.  Anyway, readers need to draw their own conclusions from the following letter prepared by the stalwart conservationist heading up the opposition to the mine, Carika van Zyl.  Last week she circulated this letter with associated documents (published here with her permission):

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Misrepresentation of N3 De Beers Pass route wetland specialist findings

13 July 2015


The De Beers Pass route is essentially untransformed and characterized by pastoral tranquillity and seclusion…

During 2013 we (DH Environmental Consulting, DHEC) undertook a significant body of work assessing numerous wetlands along the route of the proposed De Beers Pass N3 Toll Road (DBPR) between Warden and Keeversfontein.  Our final report, detailing our assessment of the impacts that would be incurred by the new road, was submitted in October 2013. We have not received any feedback thereon since that time.

We have recently learnt, via reviews of our and other specialist environmental impact assessment work conducted for the proposed new road, that our findings were not carried over into the Draft Environmental Impact Report (DEIR) or for the Draft Integrated Water Use Licence application (DIWULA) (these reviews may be found here).  One of the reviews concludes as follows:

The Draft EIA Report does not adequately reflect the findings of specialist studies. There have been material omissions and in general specialist findings have been watered down, with the exception of those relating to economic impacts. This is particularly true of those studies which show significant adverse impacts – these have been summarised to the extent that their significance is under-stated and preferred mitigation measures involving avoidance of impacts discarded. Accordingly, the obligation to conduct work in an objective manner as required in terms of regulation 18(c) of the 2006 NEMA EIA Regulations has not been achieved. Economic benefits, which are beneficial to the application have been fully stated (e.g. Chapter 11 of the Draft EIA Report) whereas the same cannot be said for significant adverse impacts as is demonstrated by some examples in Table 2 in this review.

DH Environmental was not provided with a copy of the DEIR or the DIWULA.  Had we been, we would have strongly contested the manner in which our findings were not carried over into these documents.

We are also extremely concerned to learn that, at public meetings, which we were not invited to attend or present our work at, the impression was allegedly created that all of the project specialists concurred with the content of the presentations being made by the Environmental Assessment Practitioner (EAP).  Furthermore that, inter alia,  the presentation of findings by a colleague wetland specialist were prevented from being shown at the public meetings (see report found here). Other alleged client intervention in the process is also documented.  We also find, from one of the reviews, that the opinion of the client – to wit casting doubt on the specialist findings – were included in the EIR.  This is wholly inappropriate and suggests a new low for EIAs.

A summary of our findings, which indicate the proposed route to be ill-advised, are provided below.  We strongly recommend that oversight by specialists become a mandatory component of the EIA and associated licensing processes – this to ensure that their findings have been correctly interpreted and included.  We can only wonder as to how many other EIAs have followed this practice and got away with it.

In our opinion, there is sufficient evidence to indicate that the EIA process for the DBPR is sufficiently flawed for it to be set aside as being materially deficient.  We hereby disassociate ourselves with the process that appears to have been followed in deriving the DEIR and the DIWULA.

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31 May 2015

Between 2009 and 2014 DH Environmental Consulting (DHEC) undertook a series of aquatic environment assessments and investigations for the proposed Sitari Country Estate development, north of Macassar, Cape Town.

This work culminated in the preparation of a concept design for the re-creation of the Klein Zeekoevlei wetland (a copy of the report may be found here).

On 10 December 2014, a blogpost regarding the wetland appeared on the Sitari website, in which was stated that Bill Harding of DHEC would be “overseeing the remediation of the wetland at Sitari Country Estate”. A full copy of the post may be found here.   The same article also appeared in SA Property News on 20 January 2015.

Bill was the wetland specialist for the highly successful Century City (Intaka Island), Capricorn Business Park, Silvermine River Flood Management Scheme and Paardevlei wetlands.

The Sitari post of 10 December 2014 was placed without our prior knowledge or consent. We condoned it, however (see our Twitterpost of 13 December 2014), on the basis of prior written indications from the developer that we would undertake the work. On 19 December 2014 an email from the developer’s agent indicated that a meeting to discuss going forward would take place early in 2015. Neither this meeting, nor any contact from the developer, transpired.

It has recently (28 May 2015) come to DHEC’s knowledge that the wetland re-creation work has since been contracted to someone else.

Accordingly we have objected to the continued, unsolicited and misleading use of Bill Harding’s name and association on their website and requested that it be removed with immediate effect.

Furthermore, we wish to place on record that we have not been involved in any of the phases that are required to take the concept ideas into a working design, inclusive of the hydrological and water quality (stormwater treatment) models.



The State of Nature in the EU: an unfavourable picture for freshwaters

26 May 2015


Avon Meadows Community Wetlands in Worcestershire, England have been created on the rural-urban fringe to encourage biodiversity, reduce flooding and improve water quality on the nearby River Avon. Image: Geoff Moore | Flickr | Creative Commons

Last week the European Environment Agency released their ‘State of Nature in the EU‘ report, which uses comprehensive data collected across the continent between 2008-2012 assess the status of and trends in biodiversity and natural habitats across Europe.  Data on Europe’s species and habitats was collected by individual countries (or member states) as part of monitoring for the Birds Directive and the Habitat Directive – European environmental policies designed to help guide conservation, protected area management and environmental restoration across the continent (more information on these at the bottom of the post).

Hans Bruyninckx, the Executive Director of the European Environment Agency said“This unique assessment is a first of its kind, building on extensive observation networks of experts and citizens alike. Despite some information gaps, it provides the most complete picture of Europe’s biodiversity to date.  The results are mixed but clear. When implemented well, conservation measures work and improve the status of habitats and species on the ground. Such improvements remain limited and patchy, and unfortunately Europe’s biodiversity is still being eroded overall and the pressures continue”

The results of the study for freshwaters are largely unfavourable.  Around half of the conservation status of river and lake habitats and species reported to the Habitats Directive are deemed ‘unfavourable-inadequate‘.  It is worth noting that the habitats and species assessed by the Habitats Directive were already deemed rare, endangered or otherwise threatened.  However, the picture is still not positive: around a third of these conservation statuses are in decline, suggesting that a significant proportion of Europe’s freshwater species and habitats face significant threats to their health and diversity.

Rivers and lakes were found to be most impacted by modifications to natural conditions (for example: river channel modification and fragmentation, water abstraction, draining of wetlands), water pollution and the impact of agriculture (e.g. fertiliser run-off).  Changes to natural conditions were particularly damaging pressures for birds which live in freshwater habitats, presumably due to a reduction in available nesting and feeding sites.

Protected area designation was reported as the most popular conservation measure implemented by member states to mitigate the identified threats for both birds and wider habitats.  For non-bird species – largely fish, invertebrates and amphibians – conservation measures were more diverse, including restoring hydrological regimes, legally protecting habitats and species, and improving water quality.

MARS project leader Daniel Hering commented on the findings, suggesting that whilst water quality in Europe is improving, any widespread improvements in freshwater biodiversity and habitat quality lag well behind:

“The negative assessment of river and lake conservation status is in line with the results of the Water Framework Directive monitoring. Both the assessment under the Habitats Directive and under the Water Framework Directive rate the status of lakes and rivers quite negatively.

The results are consistent but also quite surprising for many people who acknowledge the great improvement of water quality in recent decades. Strong pollution has vanished from European rivers and lakes – but biodiversity and ecosystem functions are still impoverished.

Freshwater ecosystems in most parts of Europe are still stressed, but the stressors are less visible than in former times. Eutrophication, pesticides, removal of riparian vegetation, water abstraction – all these stressors affect a large proportion of Europe’s waters. In former times the wastewater from households and industries were the main threat; nowadays, it is the way we practise agriculture.”

Read the State of Nature in the EU Report online

The Birds Directive and the Habitats Directive

The Birds Directive was set up in 1979, and aims to protect all wild birds with natural ranges inside Europe, and identifies 193 species which are in need of special conservation measures due variously to rarity, threat of extinction or loss of habitat.  The Birds Directive also requires European member states to designate Special Protection Areas for the conservation of endangered bird species.

The Habitats Directive was set up in 1992 with the aim of ensuring the conservation of rare, threatened or endemic species of plants and animals across Europe.  The Directive covers over 1,250 species and 233 habitat types across the continent, and requires member states to designate and manage Special Areas of Conservation and implement other management measures to restrict the taking, capturing or killing of important plant and animal species.

Re-posted with the kind permission of thefreshwaterblog

Hydrocitizenship: A passport to civil society awareness of water and aquatic ecosystems

16 March 2015

Image: Hydrocitizenship

Image: Hydrocitizenship

Hydrocitizenship is a UK project, funded by the Arts and Humanities Research Council, which seeks to investigate the relationships between water and humans through a number of creative, interdisciplinary approaches.  The project website outlines that: “The term ‘hydrocitizenship’ has been adopted in reference to the more established notion of “ecological citizenship” which sees transformations in how society works at individual and collective levels as essential if we are to generate more meaningful, ecologically sustainable forms of society. In our project, we put this idea to work within the contemporary contexts of individual and community engagements with water.” Read more »

R25 million spent to quietly drain a wetland

1 July 2014

Balamhlanga Vlei (Source: GoogleEarth).

Balamhlanga Vlei (Source: GoogleEarth).

The Balamhlanga Pan (Latitude: 27.4S / Longitude: 32.2E), a vlei-wetland northeast of Mkuze in KZN, adjacent to the Pongola River, has been curiously drained – or is in the process of being drained.  I say ‘curiously’ as the scarce information available about this incident does not suggest that approvals were granted for this apparent environmental injustice. A 16 June 2014 report on the website of the KZN Agricultural Union notes the concerns raised by the SA Wetland Society and others, follows a report on the incident published in Rapport of 14 June.  Yesterday (June 30th), Beeld and The Witness carried similar copy on the matter. Read more »

Can agriculture and water resources exist in harmony in a densely-populated world?

4 June 2014

A Space for Water in the Common Agricultural Policy (CAP)

River Great Ouse in arable farmland. © Copyright Hugh Venables and licensed for reuse under this Creative Commons Licence

River Great Ouse in arable farmland. © Copyright Hugh Venables and licensed for reuse under this Creative Commons Licence

A recent European report suggests that attempts to promote freshwater ecosystem conservation in European agricultural policy have so far proved largely unsuccessful.  The report, published in May 2014 by the European Court of Auditors (pdf), describes how priorities for freshwater ecosystem conservation outlined in the Water Framework Directive (WFD) have yet to be successfully integrated into the Common Agricultural Policy (CAP). Read more »

Offsets for allowing wetland loss: Playing God with Nature?

14 March 2014

Can we presume to allow more wetland loss than has already occurred? (Photo: Bill Harding)

Can we presume to allow more wetland loss than has already occurred? (Photo: Bill Harding)

One of the more controversial debates in ecology in recent times centers on whether or not it is possible to find offsets for allowing the loss of natural habit, be it ancient woodlands, areas of coastline or wetlands.  Impacts on the latter are often driven by mining demands – especially for the coal seams that are commonly located beneath wetland systems. Read more »

Greyton Common: DEADP Minister agrees with residents concerns

22 February 2014

Evening over the Greyton Common (Photo: Bill Harding)

Evening over the Greyton Common and the Qobos River Bridge (Photo: Bill Harding)

During August 2013, residents of Greyton became aware of an arrangement, between the Theewaterskloof Municipality (TWKM) and the Department of Rural Development and Land Reform, whereby a substantial portion of the commonage along the Qobos River, was sold to provide land for a land claim.   As the land and the adjacent river and wetland environments are of considerable ecological importance due to their type and rarity, and in the absence of any apparent EIA process or public participation, concern was voiced via a letter to Minister Anton Bredell of the Department of Environmental Affairs and Development Planning. Read more »

Coastal wetlands at greater risk from man than from sea level rise

30 December 2013


Coastal wetlands can cope with sea-level rise, providing man allows them to (Photo: Bill Harding)

While man is deemed to be  the most intelligent life form on earth (debatable but there it is…), man also is responsible for wilfully destroying the environment of this sphere that we live on.  This assault on our natural capital is particularly, but not exclusively, relevant to the ecosystem services provided by coastal wetlands.

A recent article in Nature reveals that while coastal wetlands have in-built mechanisms to allow them to compensate for rising sea levels, they cannot attenuate the impacts of land-based and marine eutrophication (nutrient enrichment) and, obviously, physical impacts from development – the latter including the reduction in transport of sediments to wetlands.  Authors Kirwan and Megonigal observe that “…observations of wetland drowning are infrequent because of the fascinating interactions between plants and soil that allow wetlands to actively engineer their position within the intertidal zone in ways that enhance ecosystem persistence“. Read more »