Transcript Content of the Presentation

IMPLEMENTATION OF THE NATIONAL
WASTE MANAGEMENT STRATEGY
Mining Industry Response
Presented by
Mr N Lesufi
Ms S Mudau
Content of the Presentation
1. Background
•
2. Implementation of the NWMS – general Issues
4. NWMS – specific issues
5. Way Forward
Background
•
The Chamber of Mines has worked closely with DEA in the policy
development space i.e. the initial White Paper on Pollution and Waste
Management.
•
The development of the subsequent legislation and its regulations have
been of greater interest to the mining industry due to the long outstanding
uncertainty of mandates from both the DMR and DEA.
•
The strategy clearly spells out the jurisdictions of the Waste Act and
excludes residue deposits and stockpile as regulated for in terms of the
MPRDA. This assertion translate to the fact that the actual strategy is not
applicable to the management of residue deposits and stockpiles.
Implementation of the NWMS , General issues
•
The current strategy needs to recognise extensive work that has been
achieved by inter alia the following policy interventions,
– White Paper on Pollution & Waste Management
– Minimum standards for the operation of landfills (DWA)
– Provincial Policies
NB: This is necessary to highlight cooperative governance, and to indicate optimisation of
government resources, etc.
•
Furthermore, the strategy must also be premised on the failures &
success of the above interventions in SA’s attempt to minimise waste,
discourage land filling & promoting cleaner production.
•
The Waste sector is a contributor to global warming and in this regard
the NWMS MUST recognise the recently approved White Paper on the
National Climate Change policy on how it will further contribute to
emissions reduction.
NWMS, specific issues
•
The definition of waste is quite problematic because it purport that
almost everything can be treated as waste which is not the case for the
mining industry i.e treatment of acid mine drainage results into gypsum
which is transformed into usable products i.e brick making, fertilizers
•
Development of standards for soil quality and remediation of
contaminated lands i.e the gazette on this standards, it is not always
technical achievable to remediate the soils and contaminated lands
whilst mining, dependant on orientation of the orebody etc. This is also
addressed in terms of the rehabilitation and closure plan.
•
Goal 1 should be revised to move away from the primary focus on the
3R approach but rather to promote the application of innovation and
best practices for effective waste management beyond the 3Rs
NWMS, specific issues
•
The NWMS is silent on reducing the number of landfills and hence there are
no incentives to apply the waste management hierarchy.
•
Goal 3 refers to growing the green economy however the narrative of the
goal in the document refers to job creation (and not even green jobs). A
specific section dealing with how this NWMS will further support the aims &
objectives of the climate change policy e.g. greenhouse gas emissions
reductions, creation of green jobs must be added
•
Also, further a key fundamental goal missing in the strategy is the need for
South Africa to employ measures leading to conversion of waste into
sustainable resources, thus minimizing the need for waste disposal
facilities, and also a goal which encourages that the waste management
sector supports economic growth of this country.
NWMS, specific issues
•
Licensing Waste Management Activities. In terms of the current
licensing regime, there has been an outcry from the mining industry on
the actual fragmentation and overlaps in terms of the requirements for
the application of the waste management license, water use license as
well as the necessary environmental requirements
•
The proposed regulatory model for waste management in South Africa
should not only focus on non compliance by industry and the punitive
measures thereof, however, this should propose a holistic regulatory
regime which encompasses wide range of instruments for all sectors i.e
transport, domestic etc
Way Forward
•
The NWMS must be a ‘current’ intervention that has taken into account
lessons learnt from past policy initiatives
•
It must take into cognisance related policy interventions e.g. approved
White Paper on the National Climate Change policy
•
It must address waste management holistically e.g. inclusion of other
sectors e.g transport, domestic etc, and
•
The definition of waste must be revised to take into consideration the
by-product which are not waste but are a resource.
•
The Chamber of Mines, looks forward to further engaging with both
DEA & the DMR in pursuit of achieving an alignment of both
legislations regarding environmental authorisation of mining related
activities.