CHAMBEROFMINESOFSOUTHAFRICA-AmazonWebServices.docVIP

CHAMBER OF MINES OF SOUTH AFRICA ________________________________________________________________________________ WRITTEN COMMENTS TO THE PARLIAMENTARY PORTFOLIO COMMITTEE ON WATER AND ENVIRONMENTAL AFFAIRS AND THE DEPARTMENT OF WATER AND ENVIRONMENTAL AFFAIRS ON THE NATIONAL ENVIRONMENTAL MANAGEMENT LAWS AMENDMENT BILL B26-2013 _________________________________________________________________________________ INTRODUCTION The Chamber thanks the Portfolio Committee on Water and Environmental Affairs for the opportunity afforded to submit comments on the above Bill. The Chamber would appreciate if its comments on the Bill could be read with the Chamber’s comments (As attached in Annexure A) on the corresponding provisions in the Mineral and Petroleum Resources Development Amendment Bill B15-2013 (“MPRDA Amendment Bill, 2013”), extracts from which comments are attached hereto for easy reference by the Committee, and which comments are therefore hereby incorporated by reference in these comments. Since the Chamber was not afforded the opportunity by the Department of Water and Environmental Affairs to comment on the draft Bill which preceded this tabled Bill, the Chamber’s comments will not necessarily only deal with matters of principle but also with matters of the drafting process, and will therefore be done clause-by-clause. As a prelude to its clause-by-clause comments, the Chamber sets out below some of the most important provisions that appear in the Mineral and Petroleum Resources Development Act, 2002 (“MPRDA”) and in the National Environmental Management Act, 1998 (“NEMA”) (both once the environmental provisions relating to prospecting, mining, exploration and production in the MPRDA Amendment Act, 2008 and the NEMA Amendment Act, 2008 take effect in terms of s94(2) of the MPRDA Amendment Act, 2008 and in terms of s14(2) of the NEMA Amendment Act, 2008 in 18 months from 7 June 2008 when in terms of Proc 14 GG 36512 of 31 May 2013 as amended by Proc 17 GG 365