Call for comprehensive study on adverse mining impacts on park
In a report on impacts of the Somkhele mine on the Hluhluwe – iMfolozi park, Ezemvelo KZN Wildlife’s Consevation Planning manager, Jenny Longmore states that Ezemvelo was legally obligated to ensure that the integrity of the protected area, its biodiversity and value to the current generation and particularly those yet to be born, is properly safeguarded.
She said it was thus important that any study on the impacts of the mining, must give cognisance of the “eternal importance of the HiP to people”, and be accurate and informative, and called upon the mining company, Tendele Coal (Pty) Limited to fund such study on the polluter must pay principal
The following is a slightly abridged version of the Ezemvelo KZN Wildlife report.
The importance and value of the Hluhluwe-iMfolozi Park
The area that is today known as the Hluhluwe-iMfolozi Park was first set aside as a Royal hunting ground in the 1820’s by Zulu King Shaka. The establishment of such a protected area nearly 200 years ago is remarkable, a world first, deserving of universal recognition in global conservation history.
The HiP is also one of the oldest formally proclaimed protected areas on the African continent, with sections of the HiP first proclaimed in 1895.
HiP is one of the few protected areas in KZN which features the ‘big five’ animals. The Park also comprises a variety of functioning ecosystems which protects diverse environmental and ecological contributors, with many of the species and ecosystems protected in terms of the National Environmental Management Biodiversity Act.
The park was also the birthplace of the wilderness movement in Africa and contains a 50-year old designated Wilderness Area.
It has an intrinsically wild appearance and character which is undeveloped and roadless, without permanent improvements or human habitation. It protects and maintains the natural character of the environment, biodiversity, associated natural and cultural resource . . . provides outstanding opportunities for solitude.
The HiP also has a “long history of innovative conservation research and development; a case in point being the central role the Park played in saving the white rhino from extinction”
As such it is enshrined in the collective conservation consciousness as one of the most important centres of conservation in the World. Today HiP’s Rhino Population is rated as one of the 6 global key populations by the IUCN African Rhino Specialist Group.
The HiP has international iconic status and is of both continental and global importance. This iconic status in global conservation cannot be measured and cannot be reduced to a monetary value.
In addition, HiP contains significant cultural heritage value in that it has a rich archaeological history with sites dating from the early Stone Age through to the late Iron Age. A few are secured within the park. The Park is internationally renowned for its Zulu heritage and as a result has a significant variety cultural and scared sites. The Park also supports a few San rock art sites.
As a protected area, HiP safeguards essential ecological goods and provides invaluable services to the surrounding communities and beyond. This includes provincial, national and international levels. In particular, it functions as an important water catchment, helping ensure water supply to downstream users as well as attenuating floods.
Its internationally recognised branding and its wildlife gives HiP the potential to support a thriving biodiversity economy.
The HiP arguably constitutes an invaluable biodiversity, cultural and historical resource worthy of the highest form of protection. It is also a key destination for international nature-based tourism and as a consequence is a significant driver of this province’s and South Africa’s foreign exchange.
Mounting land use change and other threats on its boundary
It is common cause that HiP is presently facing mounting development pressures from land use change outside the Park. The advance of landscape change (mining as well as rural housing projects) onto the Park boundary is and will adversely impact on the values, purpose and management effectiveness of the HiP and threatens to foreclose on establishing and enhancing rural economies based on the biodiversity economy.
It is also evident that the communities adjacent to HiP live in predominantly extreme poverty, restricted job opportunities and poor service delivery from other State entities. This circumstance places a huge burden on the HiP to assist these communities alleviate their economic and social challenges.
Longmore states that the protected area is being negatively impacted upon by development and land use change in the adjacent areas. “While it is recognised that each of these impacts may be seen or demonstrated to be trivial, the exact opposite prevails from a cumulative impact perspective,” said Longmore.
Positive impacts of the Somkhele Mine
We cannot dispel the fact that the Somkhele Mine is an existing mine on the boundary of the HiP and that despite the global imperative to move away from the extraction and use of fossil fuels, there is seemingly still a demand for coal and in particular anthracite coal. It is also acknowledged that despite full and part time employment figures being less than the HiP (and jobs being restricted to the life-of the-mine), the mine was a major employer in an area that currently offers restricted job opportunities.
Projects associated with the Social Responsibility Programme of the Somkele Mine, such as the establishment of schools and clinics were a positive spin-off from the mine. A recent initiative to assist local people in obtaining their drivers licenses was also a clear example of the mine trying to support, ‘give-back’ and capacitate the community.
Somkhele Mine responded to calls for assistance when the water supply at Mpila Resort ran dry. Water tankers were dispatched from the mine to provide water to the Mpila Resort and staff outposts.
Longmore said Tendele Coal (Pty) Ltd was presently constructively engaging with Ezemvelo about the establishment of biodiversity-offsets to be located adjacent to the HiP.
The establishment and longterm security of areas adjacent to the Park is deemed to be very positive and will serve to fulfil a number of pressing objectives.
This included providing a layer of protection to the HiP) and safeguarding the integrity of the protected area, park expansion goals and targets, climate change resilience and creating a platform for establishing and enhancing rural economies based on the biodiversity economy.
Negative impacts of Somkhele Mine on the HiP
However Longmore state that positive attributes and benefits of the Somkhele Mine, did not in Ezemvelo’s opinion, outweigh the negative impacts the mine is having on the Park.
“Ezemvelo has observed in a number of instances that the Somkhele Mine is impacting directly on a number of the specific values and purposes for which the protected area was proclaimed, namely:
- Conserve the ecological integrity and the wild character of the Park
- Conserve the integrity of the iMfolozi Wilderness Area
- Safeguard the Scenic beauty and outstanding aesthetic value of the area
- Contribute local, regional and national economies through the provision of ecosystem services, eco-cultural tourism, and the sustainable use of natural resources
- Provide a major destination for eco-cultural tourism in SA
- Provision of Ecosystem Services including water supply, soil stability, protection of important catchments, water security, carbon sequestration and many others.
Longmore said that the “cumulative and compounding impacts on the Somkhele Mine on the HiP, and the iMfolozi Wilderness Area in particular, had only recently been realised.”
Longmore said the report had been compiled “in the spirit of alerting the mine to the impacts and externalities that the mine is having on the HiP, with the purpose of working together to resolve and mitigate as far as possible the current impacts of the Somkhele mine on the HiP and its buffer zone”.
Impacts on road safety
Ezemvelo has received several verbal complaints from visitors to the HiP (both South African and foreign) that the sense of arrival to the provinces flagship Big 5 Reserve is marred by the Somkhele Mine. Complaints from visitors included road safety concerns. Visitors to the HiP are having to share the main access road to the HiP with large coal trucks. This resulted in visitors being frustrated at being stuck behind slow moving and dirty coal trucks, as well as speeding coal trucks, well above the 80 km speed-limit, damage and deterioration of road surfaces due to heavy usage by coal trucks and coal dust pollution lining the roadside gutters as well as vegetation growing adjacent to the R618. This was not only aesthetically unattractive, but also an environmental concern).
Sense of place concerns
Many visitors had also expressed both disappointment and dissatisfaction that the rural character of the approach to the HiP and the sense of arrival to the HiP has been marred by the mine.
Ezemvelo recognises that the ‘sense of place’ of the approaches to protected areas is important, if not critical, in establishing a sense of arrival and ultimately an appreciation of the protected area. It is for this reason that Ezemvelo views the approaches to protected areas as a critical asset to be conserved and protected and where necessary restored.
This consideration includes but is not restricted to, all views of the mining landscape, use of the provincial road to and from the protected area’s tourism gate by mine trucks, coal dust emanating from both the mining operation and the coal tracks cumulating on the road, road verges and adjacent vegetation, and noise generated by the mining operations inclusive of blasting.
Negative impact on visitor experience and tourism appeal
The tourism value of HiP is reliant on providing visitors with the increasingly rare opportunity to experience and enjoy intact wilderness and a natural bush experience, inclusive of unspoilt viewscapes, soundscapes and naturally dark skies.
Ligths and noise from the mining operations had adversely impacting on the values of the protected area and the product offering and experience of guests.
The Somkhele Mine was arguably the most significant single source polluter in the area, especially with regard to noise and visual intrusions.
While impacts have been noted since the inception of open cast mining activities in 2007, the impact on the Park has progressively increased since that time.
The northward extension of the mine is distinctly visible with a naked eye from tourism roads in the iMfolozi section of the Park as well as from Mpila Resort.
Tourists notably use binoculars and telescopes in protected areas which exacerbates the visual impact of the mine on their experience.
The noise and visual intrusion (day and night) into the iMfolozi Wilderness Area is significant in that it is constantly noted by visiting trailists, seeking a wilderness experience, and Ezemvelo staff.
To this end, Ezemvelo initiated basic monitoring and auditing of noise and visual intrusions into the Wilderness in 2009. It is an undisputable fact that lights from the mine can be seen from a number of sections of the iMfolozi Wilderness Area, and that this impact has worsened since the mine started operating 24 hours a day in or about 2012.
The noise impacts on the iMfolozi Wilderness Area had also considerably worsened since the mine began operating 24 hours a day.
The much lower ambient noise levels in the wilderness at night results in mining noise being carried further into this area as well as it being more prevalent.
An analysis of wilderness noise records shows that the Somkhele Mine could be heard from as many as 30% sites audited in the years 2009 to 2010. “Wilderness monitoring data shows a marked increase in the sound of heavy machinery heard from trails within the iMfolozi Wilderness Area towards the end of 2011.
“In February 2012, the Wilderness Leadership School (WLS) reported that increased noise from the Somkhele Mine could be heard from almost everywhere within their concession area. Trailists regularly complained about the noise, especially during their night watch and solitude times.
The WLS also reported that they tried camping in varying locations (thicker bush and lower down adjacent to the Black iMfolozi River) in an attempt to escape audible noise of the mine.
Only one site was found to be relatively protected from the sound of heavy machinery at night, which was attributed to the Nceba hill (a hill located within the iMfolozi Wilderness) which served to block the sound of the mine. From as early 2012, staff staying at the Makhamisa Outpost on the southern edge of the iMfolozi Wilderness Area reported noise disturbances from the Somkhele mine – a general ‘hum’ from the mine and infrequent loud noises at night
In 2017 noise impacts worsened as the mine expanded northwards. From 2018 onwards, noise from the mine was clearly audible during the day. In the years 2017 – 2019, the percentage noise heard at the various audit sites increased to between 52 – 60% of all sites audited. In response to noise and visual impacts, Wilderness Trails Officers are now forced to purposefully plan routes so as to avoid, as far as possible visual intrusions. It is virtually impossible, however, to avoid noise impacts.
Wilderness Trails Officers have postulated that the seemingly lower game numbers in the wilderness over the past 10 years, is also impacting on trailists wilderness experience. While it is extremely difficult, if not impossible, to demonstrate a causal link between the activities of the mine and decreased game densities, it has been demonstrated that human induced noise, ground vibrations and light disturbance is a contributing factor in the avoidance of certain areas by a variety of wildlife species, or increased stress (e.g. elephants) and death in others (e.g. crocodiles).
It is also acknowledged that other species of wildlife may become accustomed, within reasonable parameters, to an ongoing and consistent noise and light pollution. This is not the case with booming noise and sudden vibrations which cause animals to take fright. In such circumstances, it has been shown that wildlife become stressed and typically display avoidance behaviour such as emigration to other less disturbed areas.
Ezemvelo has learned that a prominent Private Boys School in Cape Town has, after 20 years of taking boys on trails in the iMfolozi Wilderness, informed the CEO of the Wilderness Leadership School, by way of a formal letter that the school will no longer be returning to the iMfolozi Wilderness Area as it no longer offers their boys a true wilderness experience. In our opinion, this is clear evidence that that the impacts of the mine on the iMfolozi Wilderness Area are not trivial.
Negative impact on critical reference site
The main reason for the iMfolozi Wilderness Area is to protect natural processes and provide a refuge for species which could be affected by humans, their infrastructure and their activities. Environmental legislation describes a wilderness area as: “an area where little or no human intrusion is permitted so that the natural processes will take place largely unaffected by human intervention.”
This definition speaks to the importance of wilderness being protected for the purpose of long-term conservation and not only for people’s experience. The importance of having natural reference sites where natural processes and animal behavior can happen without human influence cannot be overstated – very few true wilderness areas persist today.
While Ezemvelo has strived to manage the iMfolozi Wilderness Area according to an approved Wilderness Management Plan, the intrusion of the Somkhele Mine into this wilderness is likely having an impact on natural processes.
Lighting impacts on fauna
Lighting impacts in the wilderness may affect animal behavior and adversely affect bat and insect interactions and cause changes in animal communities. Artificial lighting could disrupt the mating systems of invertebrates that are attracted to light such as stars and moonlight.
Noise impacts on fauna
There remains significant uncertainty as to how the fauna will react to even small changes in ambient noise, especially given the different hearing characteristics and perception of animals to noise It is quite possible that the constant operational noise pollution from the Somkhele Mine into the Wilderness, 24/7 and 365 days a year, will impact on fauna. Birds, insects and mammals who use calling systems to advertise territory or attract the opposite sex could be affected.
A further concern is the possibility that the constant noise disturbance in the Wilderness could compromise the breeding success of vulture species, birds of prey and other species of conservation concern such as Southern Ground Hornbill, which nest in relatively proximity to the reserve boundary.
Vibration impacts on fauna
Vibrations associated with the proposed mine could very likely have an impact on all forms of wildlife, from insects to birds and large mammals. Vibrations may have a significant impact on elephant behaviour (as major form of communication is through vibrations in the ground. Crocodiles are highly susceptible to vibrations, in that their jawbones are close to the ground surface[1]. Reduced breeding success in crocodiles as a result of stress caused by vibrations is a concern given that crocodiles do nest in the wilderness.
Coaliferous dust pollution
Ezemvelo has received reports from trail guides of a black powder substance that has been observed in the wilderness that resembles coal dust. Regrettably the necessary samples and tests to confirm whether the back dust is indeed coal dust has not been undertaken. Based on the literature, fugitive dust emissions released during mining operations are reported as of concern within 3 – 5 km of the mine boundary. While the Somkhele Mine (Area 2) is located just further than 5 km from the Park boundary, the meteorological conditions of the area (dominant wind direction from the north-north east and strong winds) suggests that wind could blow dust emissions directly into the wilderness. The possibility and extent of coal dust intrusion into the Wilderness, and the impacts and significance thereof, requires investigation. Given the purpose of the wilderness, it would be of heightened concern if the deposit of coal dust and any other mining related mineral in this area caused behavioural and productivity changes in flora and fauna or caused changed in ecosystem functioning as has been demonstrated in areas adjacent to open cast mines elsewhere.
It is acknowledged that Ezemvelo has not undertaken the studies to determine the significance of the impact of the Somkhele Mine on the protected area. In accordance with the principles underpinning the environmental impact process and the relevant provisions in common law, this onus lies with the mine (i.e. the polluter pays principle) to undertake or cause studies to be undertaken that assess the presence and significance of the externalities of the mine. The responsibility of Ezemvelo is to draw on its experience and professional expertise to highlight and make known the concerns it has and to create an enabling environment for the required research. In the absence of definitive and conclusive studies, the precautionary and risk-averse principle must be applied in favour of the protected area. Hence the claim that the Somkhele Mine is having a detectable impact on the iMfolozi Wilderness Area and this may be negatively influencing the distribution and wellbeing of wildlife must be assumed until it is shown to the contrary.
Mine diminishing the ecosystem service value and function of the HiP to communities
Studies on the ecosystem services function of the HiP have confirmed that the HiP provides an important water service function to the surrounding communities and beyond. In particular, it functions as an important water catchment, helping ensure water supply and water quality services to downstream users as well as ameliorating floods. An ecosystem services assessment conducted by Ezemvelo in 2015 showed a high reliance of communities on the provision of ecosystem services provided by the HiP. Ezemvelo’s Community Conservation Officers have advised that communities living in proximity to Somkhele Mine are complaining of reduced quality and quantity of water, which they attribute to the Somkhele Mine. While these allegations have not been investigated by Ezemvelo, water concerns in such proximity to the HiP does serve to diminish the community’s appreciation of the ecosystem service function provided by the HiP, which naturally is of concern as the ecosystem service function serves, in part, to vindicate the existence and importance of the Protected Area
Rhino security and Ezemvelo’s wildlife crime operations in HiP
The current scourge of rhino poaching is having a significant negative effect on the rhino population in the HiP. For security reasons we cannot divulge the number of animals that have been poached in the Park, but the preferred population growth is not being achieved and the population is in decline which is of huge concern.
The section of the Park proximate to the Somkhele Mine is a rhino poaching ‘hot spot’ zone. While it is difficult to determine the cause of this phenomenon, the following factors are generally believed to contribute to high poaching incidences:
- Night-time lighting from the mine has increased the “window period” available for rhino poachers to actively hunt rhino and their ability to enter/exit the Park after night fall.
- The improved/increased road network and the influx of non-local vehicles makes it very much easier for suspects to mingle into the community along the fence between Nyalazi and Siyembeni Crossing (which is directly adjacent to Somkhele Mine).
- The high taxi and truck traffic between the N2 and the Somkhele Mine are seemingly assisting poaching syndicates in moving around without being detected. (Most of the poaching syndicates emanate from Mpumalanga. It is relatively easy for poachers to remain undetected until they get onto the N2 and head to Mpumalanga).
If the above assumptions are correct, as we believe them to be, this is a clear case of externalities from Somkhele Mine becoming internal costs for Ezemvelo. Ezemvelo (and our NGO partners) are directing an inordinate amount of money into additional security and law enforcement interventions in the HiP, in a desperate attempt to combat the increased poaching threat. These funds could be better spent if directed into the iMfolozi Biodiversity Economy Programme and “Amathuba Zone” for example, which aims to provide meaningful, tangible benefits for communities made possible by the protected area.
Noise emanating from Somkhele Mine is having an impact on Ezemvelo’s wildlife crime operations in the HiP and thereby indirectly on rhino security. On many an occasion, antipoaching officers have responded to what was thought to be gun shots, but later established to be noise emanating from the mine. (The flap on the back of mine vehicles load-bin reportedly makes a sound like a gun shot after tipping coal deposits). This is clearly a highly undesirable situation at it places an unnecessary burden on Ezemvelo’s anti-poaching team. Likewise the noise pollution emanating from the mine at night, in particular, also serves to mask the noise generated by poachers in the protected area.
Financial and economic repercussions of a diminished wilderness
The HiP is Ezemvelo’s primary source of private income that complements the grant provided by Treasury. A diminishing wilderness and visitor appeal will likely (as the Bishops case illustrates) culminate in financial / economic implications for Ezemvelo and private concession and tourism operators within the HiP, as it will no longer be a destination of choice. Once the Wilderness is perceived by the public to be “lost”, it will likely prove to be very difficult to convince the public otherwise. Loss in revenue will not be limited to HiP’s tourism operations, but will likely extend to and affect the regional tourism industry associated with the HiP and foreclose on the creation of viable economies and niche markets for adjacent communities made possible by the protected area.
A further consideration is the loss to society of the wilderness experience, and the concomitant loss with respect to the rejuvenation of physical, mental, psychological and spiritual well-being of people, which studies have shown can be used to benefit societal behaviour and indeed the socioeconomics of the country.
