We have a small window of opportunity – until Tuesday 15 March 2016 – to make submissions on the uranium mining rights application of Tasman RSA Mines, which is set to destroy more than 500,000ha of Karoo farmland and contaminate the last remaining groundwater.

Beaufort West will be the epicentre of millions of tons of radioactive uranium ore. This cannot be the future for the Central Karoo!

Please register your objections, as an interested and affected party, to the company contracted to do the Environmental Impact Assessment (EIA), Ferret Mining and Environmental Services.

Below we have provided a few examples of reasons why uranium mining should not go ahead. Rather than copying and pasting, please rephrase to increase effectiveness, choosing a few issues from the list and adding your own concerns.

Your submission must be addressed to Tim van Stormbroek, Ferret Mining and Environmental Services (Pty) Ltd, at tim@ferretmining.co.za or info@ferretmining.co.za.

Please use ref: DMR References EC30/5/1/2/2/10029MR , WC30/5/1/2/2/10072MR, WC30/5/1/2/2/10073MR, WC30/5/1/2/2/10074MR, WC30/5/1/2/2/10075MR,
…and kindly copy your submission to us at stefancramer@gmail.com. You can find the entire application with specialist reports here.

Access to information

We believe the commenting period was not properly announced. Application documents were not sufficiently made available to the general public. The notice of public consultations was too short. Invitations for public participation process were not delivered to all Interested and Affected Parties. The cut-off date for submissions was not announced to the public. We believe the Environmental Practitioner (EP) violated the clear distinction between EP and applicant. Earlier comments from the Scoping Process were not followed through. The quality of presentations during the consultations was unacceptably poor.

The application documents are not sufficiently specific and the application area was not clearly spelled out. The application documents themselves are often of poor quality. The impacts studied covered only a small fraction of the application area. The huge size of this application points to the fact that this oversized application must undergo by its very nature a Strategic Environmental Assessment (SEA), not just an ordinary Environmental Impact Assessment.

Water Usage / Impact on Ecosystems

The project’s water consumption of the Central Processing Plant (CPP), plus the different mine sites, is far in access of current water abstraction in the Central Karoo. The specialist study for hydrology/groundwater is deficient. It uses a simplistic model to project the ground depression cone from the mine sites at Ryst Kuil and Riet Kuil, whereas it is common knowledge that aquifers in the Karoo are often linear and highly unpredictable.

Wastewater / Tailing Dams

The plan to pump contaminated wastewater from the CPP and the mine to evaporation ponds on tailings dams is not acceptable. High evaporation in the Karoo will lead to fast wind erosion. In addition, raised tailing dams have been shown to be unstable under catastrophic weather events. Their failure will send toxic and radioactive waste into the drainage systems, affecting people and nature even beyond the Karoo due to the inland nature of the mine sites.

Raised tailing dams are an eyesore to the uncluttered landscape of the Karoo and will impact negatively on the tourism income and employment. On average 50 tailings dams burst per decade, with usually horrific consequences. These tailings dams hold radioactive substances. The EIA/EMPr does nothing to address the special risks from bursting tailing dams or dust emissions from dried-out tailings.

Dust / Noise

Drilling, blasting and long-distance hauling will inevitably create a wide footprint of dust and noise far beyond the immediate mine sites. Hundreds of kilometres of trucking routes on dust roads for hazardous loads will acerbate the footprint to every corner of the three affected municipalities. The models used for dust dispersal do not sufficiently take into account strong and changing winds of the Karoo and the dust generated during trucking and off-site stockpiling. Some mining areas immediately border on the Karoo National Park (KNP).

Uranium mining will severely curtail the necessary expansion of the park and its attractiveness to the general public, as the proposed mine site lies directly in the viewshed of the park. You don’t want to watch lions in their natural habitat while drilling and blasting sends dust clouds into the air and the noise level scares animals away. The Specialist Contribution: Noise (Appendix 17) is like most other so-called specialist contributions a simple desktop study, charting the legislative framework, citing field studies elsewhere and presenting theoretical “attenuation over distance” diagrams, showing how noise would decay with the distance from the source.

Neither wind nor other environmental factors like topography and vegetation have been considered. Every visitor to the Karoo knows how differently noise travels under different conditions. No noise assessment has been conducted on the drilling rigs.

Traffic

Long-haul of uranium ores across dust roads in the Karoo will inevitably impact areas much further away from the actual mine sites. Roads will be damaged; accidents and road-kill will increase. In addition, trucks will convey radioactive dust further through the Karoo. The current calculations of traffic and its impact are unreliable and do not take into account the cost to other users and the road maintenance, already insufficiently funded from public budgets. “The Specialist Contribution: Traffic Impact Assessment” (Appendix 15) only considers traffic at one mine site (Ryst Kuil) and presents current data traffic from just one day counting, but makes sweeping statements that the rural roads can handle the extra traffic. The study does takes into consideration only the traffic as indicated by the mine itself and no other additional traffic due to regional development of the area.

Radiation / Health Impacts

We find it unacceptable to separate the radiation-related issues from the current EIA/EMPr process. To discuss uranium mining without reference to radiation and radioactive substances is like discussing a road without reference to the traffic it carries. We demand that the public participation process allow for a holistic and comprehensive approach to interrelated issues. All evidence from other uranium mining districts show the wide-spread and unmitigated impact of low-level radioactive substance dispersal, leading to measurable and demonstrable public health impacts.

Socio-economic / Job losses

While the mine proposes to create some 250 permanent jobs, it does not disclose the nature of these jobs. Many of them will involve qualifications not easily available locally. The study thus fails to model the number of job losses in agriculture, tourism and renewable energies. A sustainable development strategy for the Central Karoo Municipality does not include uranium mining. Other Integrated Development Plans even denounce uranium mining as destructive and incompatible with long-term economic recovery.

The “Specialist Contribution: Socio-Economic Impact Assessment” (Appendix 14) is silent on job losses and deficient in numerical modelling of the net employment impact. It does not even properly state the numerical values of positive impacts through mine job generation. None of the Integrated Development Plans for the Central Karoo (Beaufort West, Prince Albert, and Laingsburg) shows any readiness or understanding of the social, political and economic upheavals that are associated with the introduction of a disruptive industry. Even worse, there is not even the beginning of a public debate about the burning issues relevant to this industry in a rural setting.

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