NEW Riviera Prospecting Right application – PLEASE HELP!

The Mining Right application in the Moutonshoek Valley has been withdrawn and Bongani Minerals has instead lodged a Prospecting Right application with the Department of Mineral Resources (DMR). Please see the background information document (BID) below.

We urge members to fill in the forms below to REGISTER directly with Withers Environmental Consultants (WEC) as I&APs by 26 April 2010 and to attend the public meeting on 28 April 2010 in thousands.

We hope that our members and supporters from other interest groups will FLOOD the DMR with objections by the thousands.

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You can also email your objections to:

The Regional Manager | Department of Mineral Resources
Attention: Ms Sibongile Kunene – email:
and cc Mr Jan Briers

The reference is:

Withers Environmental Consultants – Attention : Mari de Villiers and Elize le Roux

Please remember that a Prospecting Right (PR) application is different from a Mining Right (MR) application, and objections are two-fold:

1.1                   objections to prospecting because prospecting itself (drilling, etc) is bad for agricultural operations, employment, the environment, the community, property prices, etc. An argument can be made for the current sense of place, which is rural, and is very likely to be significantly impaired by prospecting activities.
Geological and mining specialists’ opinion is that likely impacts of invasive methods of prospecting include: noise, air pollution caused by dust, possibly contamination of surface and ground water, the excavation of soil and the generation and storage of solid waste, and the possible degradation of natural vegetation, the cumulative effect of which is likely significantly to impact on the receiving environment. The application proposes a prospecting time frame of 5 years with invasive drilling processes spread over 2 years! They intend to ‘develop 150 drilling sites’, with all the concomitant infrastructure, e.g. drilling rigs, of which as many as 4 will be in place on the affected farms at one time. These invasive processes will render at least two affected farms inoperable, with an immediate loss of 320 jobs, mostly women workers.
Legal opinion is that both the principles of NEMA and, potentially, some of the listed activities under NEMA are relevant to the prospecting application.  In addition there are probably other environmental legal requirements which must be met before prospecting can lawfully commence.  These may include rezoning under LUPO, the granting of a waste management licence under the Waste Act and the undertaking of a Heritage Impact Assessment (HIA) under the National Heritage Resources Act (NHRA).

1.2       objections to prospecting because the intended outcome, mining, would be bad for agricultural operations, employment, the environment, the community, property prices, etc.

Importantly, a Prospecting Right application does not entail an Environmental Impact Assessment  (EIA) but the application does have to submit an Environmental Management Programme (EMP) for the prospecting.

Opportunities to participate and comment

Public meetings:
22 April – Focus group meeting (CBO and NGO representatives) in the Committee Room of the Centre for the Book, Victoria Rd, Cape Town CBD.
28 April – Public Open Day at Piketberg Public Library

Official closing dates for comment directly to the Department of Mineral Resources (DMR):
30 April 2010 for comment on the Prospecting Right (PR) application
30 May 2010 for comments to the Environmental Management Plan (EMP) submitted with the PR

However, for Withers Environmental Consultants (WEC) to take cognisance of objections and to include these in their primary submission to the DMR, please register with WEC and comment by:

26 April 2010 for comment to the Prospecting Right application
18 May 2010 for comments on the Environmental Management Plan (EMP)

The Draft Prospecting EMP should be available for I&AP comment from Monday, 19 April 2010 to Tuesday, 18 May 2010 at the following publically accessible places:

  • National Library, Queen Victoria Street, Cape Town;
  • Piketberg Public Library;
  • Elandsbaai Hotel; and the
  • Karookop School Office.

The document will also be available on the following website:

Dismissal of the recent Winelands prospecting right application

In response to the recent Winelands prospecting right application by government-owned African Exploration Mining and Finance Corporation, Advocate Sandile Nogxina – director general of the Department of Mineral Resources – went on record saying that an application to mine land under agricultural production would never be granted as the government had to balance the interests of the exploitation of mineral resources with food security. In his words:

“Land use has to cater for both. The land is being used for food security and there is no way we can interfere with that. We are a responsible government after all.”

“Definitely the application is not going anywhere, as, if mining went ahead, we would have to expropriate those farms and the operations. … They did not know that there were vineyards there when they made the application — they just used a geological map.”

We expect that the department will be equally responsible about the current farming activities in the Moutonshoek Valley and the value of the Krom Antonies River water catchment upstream from the sensitive Verlorenvlei wetland.

We thank you for your support!