Landowner Moutonshoek Investments legal submission on Draft EMP

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12 enriched mineral allanite. Scheelite and molybdenite occurs as fine disseminations, but also as coarse grains within cross-cutting, late stage quartz and calcite veins in the granite and the wall rocks.’ (Rozendaal, 25 May 2009). 29. In addition the prospecting information is required to “refine the current mine model and to investigate the feasibility of potential underground, instead of open cast mining.”. No information is however provided on this so-called “current mine model” that needs refining. 30. It is the Objectors’ <strong>submission</strong> that the Applicant has provided absolutely no substantial justification for applying for a prospecting right. On its own <strong>submission</strong> the purpose of the prospecting right is not to establish the quantity and location of the minerals applied for but to “develop a mine based on information gathered from the prospecting programme”. The Objectors vehemently oppose the development of any mine and regard this application as another futile attempt to obtain mining rights over agricultural land located in an environmentally sensitive area. 31. In the Objectors’ opinion the rest of the EMP is completed in general terms and does not provide any substantial information that would enable the DMR to make a wellinformed decision. The Objectors also wish to refer to a few inconsistencies and/or misinformation contained in the EMP: (i) It is stated that the area of each drill site that will be disturbed will be approximately 60m² in extent. Taking into account that the two water pits alone would be 12.5m² in extent it is questionable if the boreholes, drilling rig, metres of 20 mm class 3 plastic pipe, a generator, mono pumps and personnel could be accommodated in the remaining area of 6m X 8m. (ii) (iii) The Applicant indicates that 8 drilling sites will be situated within 1km from farm houses. Based on the diagram for drill sites provided it is the Objectors <strong>submission</strong> that 81 drill sites will actually be situated within 1 km from 7 farm houses and another 35 drill sites within 1 km from a further 4 farm houses. The statement by the Applicant that the impact upon agricultural land and the disruption of agricultural activities LITTLE SWIFT INVESTMENTS // NAMAQUASFONTEIN BOERDERY TRUST: OBJECTION AGAINST PRA WC434
13 during prospecting will be low (negative) is rejected. On the circular area alone where lucerne is grown that provides fodder for the breeding horses no less than 18 drill sites are envisaged! The impact upon agricultural land and agricultural activities in the opinion of the Objectors will therefore be high. 32. In the Objectors opinion the most glaring omission from the EMP is a reference to the area and its environmental importance. The envisaged Prospecting Area is located north of the slopes of the Piketberg and is surrounded on its southern, eastern and western boundaries by the mountains. These mountains form a natural catchment area for the Krom Antonies River and the subterranean aquifers that provide water and life for the entire area right up to Elandsbay. To argue that the envisaged prospecting activities and the ultimate mining objectives would not negatively affect this invaluable eco-system constitutes, in the Objectors’ opinion, a complete disregard of the value of this catchment area. It is submitted that the drilling of 160 plus holes 250 m deep and traversing this area and the eventual developing of an open cast mine over an area of 55 ha shall lead to the ravaging of this life-giving eco-system, with irreversible consequences . To even suggest that complete rehabilitation would be possible clearly portrays a total ignorance of the devastating effect the envisaged prospecting and the ultimate objective will have on this area. The Applicant however deems it not necessary to address this material issue. 33. Other aspects emanating from the EMP will be dealt with under separate headings elsewhere in the <strong>submission</strong>. THE APPLICANT’S STRUCTURE 34. The Applicant, Bongani Minerals (Pty) Ltd, that was initiated with the exclusive intention to prospect and mine the mineral deposit in the <strong>Moutonshoek</strong> Area, is described as a 51% BEE owned company. Its shareholders are as follows: Riviera Tungsten (Pty) Ltd – 49% T da Silva Pikwane - 37.74% POR Sehunelo - 10.20% Dikgosi Diamonds CC - 2.55% LN Kau - 0.51% LITTLE SWIFT INVESTMENTS // NAMAQUASFONTEIN BOERDERY TRUST: OBJECTION AGAINST PRA WC434
Page 1 and 2: 1 OBJECTION AGAINST APPLICATION FOR
Page 3 and 4: 3 (i) Supplementing the Objectors
Page 5 and 6: 5 clear that this information shoul
Page 7 and 8: 7 18.10 The Application does not co
Page 9 and 10: 9 23. Prospecting method: 22.1 When
Page 11: 11 EMP document. The project specif
Page 15 and 16: 15 (i) “The Applicant and the res
Page 17 and 18: 17 either by way of a loan agreemen
Page 19 and 20: 19 ZONING OF THE PROPERTY 71. Farm
Page 21 and 22: 21 (iv) LUPO is ‘relevant law’
Page 23 and 24: 23 Riviera Deposit ranked 140 th ou
Page 25 and 26: 25 PUBLIC RESPONSE 97. It can be un
Page 27: 27 this application should be cons

Landowner Moutonshoek Investments legal submission on Draft EMP

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