Challenges and enablers of a strong and sustainable 
junior coal mining sector in South Africa 

 

 

 

 

 

 

 

 

Festus Puso Leteane 

WITS Business School 

 

 

 

 

 

 

 

 

Thesis presented in partial fulfilment for the degree of Master of 
Business Administration to the Faculty of Commerce, Law, and 

Management, University of the Witwatersrand 
 

September 2022 

 

 



 ii 

DECLARATION 
 
I Festus Puso Leteane declare that this research report entitled ‘Challenges and enablers 

of a strong and sustainable junior coal mining sector in South Africa’ is my own unaided 

work. I have acknowledged, attributed, and referenced all ideas sourced elsewhere. I am 

hereby submitting it in partial fulfilment of the requirements of the degree of Master of 

Business Administration at the University of the Witwatersrand, Johannesburg. I have 

not submitted this report before for any other degree or examination to any other 

institution. 

 

 

Festus Puso Leteane  

Signed at Johannesburg on 9th September 

2022 

 

 
 

Name of candidate Festus Leteane 

Student number 9910706F 

Telephone numbers 0766081591 

Email address leteanef@gmail.com 

First year of registration 2019 

Date of proposal submission 18 January 2021 

Date of report submission 09 September 2022 

Name of supervisor James George 

 



 iii 

ABSTRACT 
 
Author: Festus Puso Leteane Supervisor: James George 

Thesis title: Challenges and enablers of a sustainable junior coal mining 
sector in South Africa 

 

        
The South African coal mining industry produces about 250million tonnes per annum, 

for the domestic and export markets. The industry is dominated by the major coal 

producers, with the top five producers producing about 80% of the coal in the country. 

It has few mid-tier producers and junior miners. The SA junior coal mining sector is 

mostly made up of single asset operating mines, located in the Witbank Coalfields, in 

Mpumalanga Province, and a few in the KwaZulu Natal province, mining anthracitic 

coal. The SA junior coal mining sector is fragmented, stagnant and not sustainable in its 

current form. Most of the junior coal miners are operating surface mining operations 

which require less upfront capital and are not costly to operate as compared to the 

underground operations. This study aims to understand the deep underlying issues that 

contribute to the challenges facing this sector, as well as the key enablers for a 

sustainable junior coal mining sector in SA. In the first objective, we investigated the 

challenges facing the sector, as well as their underlying root causes. In the second and 

third objectives, we established the key enablers and a roadmap necessary for a 

sustainable junior coal mining sector in SA. The literature highlighted the lack of 

enabling mineral policy as an underlying root cause of the challenges facing the sector. 

However, the study revealed that, the lack of access to funding remains the persistent 

and main challenge facing the sector as lot of effort has gone into improving the mineral 

policy, and the lack of execution in the process of policy implementation remains an 

obstacle to unlocking the key enablers of a sustainable junior coal mining sector in SA.  

 
 
Keywords: sustainable coal mining, mineral policy, challenges and enablers, junior miners 
 

 

Johannesburg, September 2022 

 

  

 

 



 iv 

TABLE OF CONTENTS 
 
DECLARATION ........................................................................................................................................ ii 

Abstract………. ......................................................................................................................................... iii 

Table of contents ........................................................................................................................................ iv 

List of tables….. .......................................................................................................................................... vi 

List of figures…. ........................................................................................................................................ vii 

ACKNOWLEDGEMENTS ..................................................................................................................viii 

Definition of key terms and concepts ..................................................................................................... ix 

CHAPTER ONE: Introduction to the research ..................................................................................11 

1.1 Introduction ...........................................................................................................................11 

1.2 Background and Context .....................................................................................................12 

1.2.1 The South African junior coal mining sector ....................................................12 

1.2.2 The challenges and enablers of a sustainable junior coal mining sector in SA
 ...................................................................................................................................13 

1.3 Research conceptualisation ..................................................................................................13 

1.3.1 The research problem statement .........................................................................13 

1.3.2 The research purpose (aim and objectives) statement .....................................14 

1.3.3 The research questions and propositions ...........................................................15 

1.4 Delimitations and assumptions of the research study .....................................................16 

1.5 Significance of the research study ......................................................................................17 

1.6 Preface to the research report .............................................................................................17 

CHAPTER TWO: Literature review ......................................................................................................18 

2.1 Introduction ...........................................................................................................................18 

2.2 The challenges facing the SA junior coal mining sector .................................................18 

2.2.1 The lack of enabling mineral policy ....................................................................20 

2.2.2 The lack of access to funding ...............................................................................20 

2.2.3 The dominance of the sector by few major producers ....................................22 

2.2.4 The lack of exploration for new coal deposits ..................................................22 

2.3 Research knowledge gap analysis .......................................................................................25 

2.4 Qualitative attributes key to the research ..........................................................................27 

2.5 Frameworks for interpreting research findings ................................................................28 

2.6 Summary and conclusion .....................................................................................................28 

2.6.1 Summary of literature reviewed ...........................................................................28 

2.6.2 Proposed research strategy, design, procedure and methods arising from the 
literature reviewed ..................................................................................................29 

CHAPTER three: Research strategy, design, procedure and methods .............................................31 

3.1 Introduction ...........................................................................................................................31 

3.2 Research strategy ...................................................................................................................32 

3.3 Research design .....................................................................................................................33 

3.4 Research procedure and methods ......................................................................................34 

3.4.1 Research data and information collection instrument(s) .................................34 

3.4.2 Research target population and selection of respondents ...............................37 

3.4.3 Ethical considerations when collecting research data ......................................38 

3.4.4 Research data and information collection process ...........................................40 



 v 

3.4.5 Research data and information processing and analysis ..................................40 

3.4.6 Description of the research respondents............................................................42 

3.5 Research strengthens—reliability and validity measures applied ..................................42 

3.6 Research weaknesses—technical and administrative limitations...................................43 

CHAPTER 4: Presentation of research results.....................................................................................45 

4.1 Introduction ...........................................................................................................................45 

4.2 The main challenges facing the SA junior coal mining sector .......................................45 

4.3 The enablers of a sustainable junior coal mining sector in SA ......................................52 

4.4 The potential of SA junior coal mining sector .................................................................53 

4.5 Conclusion .............................................................................................................................53 

CHAPTER FIVE: Discussion of research findings ............................................................................54 

5.1 Introduction ...........................................................................................................................54 

5.2 The challenges facing the junior coal mining sector .......................................................54 

5.3 The enablers of sustainable junior coal mining sector ....................................................58 

5.4 The potential of SA junior coal mining sector .................................................................59 

5.5 Conclusion .............................................................................................................................59 

CHAPTER SIX: Summary, conclusions, limitations, and recommendations .................................62 

6.1 Introduction ...........................................................................................................................62 

6.2 Summary .................................................................................................................................62 

6.3 Conclusions ............................................................................................................................67 

6.4 Limitations .............................................................................................................................69 

6.5 Recommendations ................................................................................................................69 

References……. .........................................................................................................................................71 

Appendices…… ........................................................................................................................................73 

Appendix 1.1:   Data collection instrument(s) ......................................................................................74 

Appendix 2.1:  Bio summary of the researcher and declaration of interest .....................................76 

Appendix 2.2:  Ethics documentation – Consent Form .....................................................................77 

Appendix 2.2:  Ethics documentation – Clearance Certificate ..........................................................78 



 vi 

LIST OF TABLES 
 

 

 

Table 1: The underlying root causes of the top three key challenges facing the sector ............................ 47 
Table 2: The key challenges facing the sector according to MINCOSA and the DMRE ......................... 47 
Table 3: Practical experience by coal junior miners in applying for prospecting rights ............................ 49 
Table 4: Practical experience by junior coal miners in applying for mining rights .................................... 50 
Table 5: Proposed solutions and other DMRE and legislature related challenges.................................... 51 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 



 vii 

LIST OF FIGURES 
 

Figure 1: Coalfields of South Africa (Hancox & Götz, 2014). ............................................................................ 11 
Figure 2: Junior miners perceived impediments to attracting investment into mining industry (Kriel, 2019)

 .............................................................................................................................................................................. 21 

Figure 3: Problem tree analysis of challenges facing SA junior coal mining sector .................................. 24 
Figure 4: The key challenges facing the SA junior coal sector according to SA junior coal miners .......... 46 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 



 viii 

ACKNOWLEDGEMENTS 
 

First and foremost, my sincere gratitude to God the Almighty, for this opportunity and 

being with me throughout the journey to complete the research successfully. 

I would like to express my deep gratitude to my research supervisor, Mr James George, 

for his patience and guidance throughout this journey, much appreciated. 

My appreciation goes to our Applied Research Project lecturer, Dr Kambidima Wotela, 

for providing structured approach to conducting research and making us believe that it 

is achievable. 

Special thanks to my employer, South32 (now Seriti Resources), for affording me this 

opportunity by funding my research. 

Special thanks to all my fellow MBA students, thanks for being there, it wasn’t easy, but 

it was worth it (the late-night hours of perseverance). 

My sincere gratitude to the owners and executives of junior coal miners, the DMRE and 

MINCOSA for your participation on the interviews as part of this study 

My sincere and heartfelt thanks to my wife, Nomsa for the love, support, prayers 

sacrifice and encouragement when the going got tough, to ensure that I complete this 

research. 

Special thanks to my two sons, Tsepamo and Tshenolo (T & T), you are the reason I 

wake up every morning and face every challenge with a smile. 

Special thanks to my parents and mother in-law, for the prayers and always reminding 

me to remain grounded and humble without saying a word. You have been and remain 

a blessing to me and my family. 

 

 

 

 

 

 

 

 

 

 



 ix 

DEFINITION OF KEY TERMS AND CONCEPTS 
 

CEO: Chief Executive Officer 

 

DMRE: The South African Department of Mineral Resources and Energy 

 

DTI: Department of Trade and Industry  

 

EA: Environmental Authorisation. This is an authorisation issued by the South African 

Department of Environmental Affairs in terms of the National Environmental 

Management Act to allow certain listed activities that have an impact on the 

environment to take place at a mine in compliance with the approved Environmental 

Management Plan 

 

IDC: Industrial Development Corporation 

 

JSE: Johannesburg Securities Exchange 

 

KZN: KwaZulu Natal Province 

 

MINCOSA: Minerals Council South Africa 

 

Mine Host Communities: This is the community living in the areas surrounding the 

mine, that need to be consulted as affected and interested parties as part of the public 

participation process before commencing with the prospecting activities or building a 

mine 

 

Mining Charter: A policy instrument, first developed in 2002 after the MPRDA, used 

to drive the broad-based-black economic empowerment and transformation in the 

South African mining industry 

 

MPRDA: Minerals and Petroleum Resource Development Act, 2002 (Act 28 of 2002) 

 



 x 

Mining Right: A regulatory permit issued by the South African Department of Mineral 

Resources and Energy, allowing individuals or companies to mine the minerals in South 

Africa, valid for up to a maximum period of 30years 

 

NORAD: Norwegian Agency for Development Co-operation 

 

Prospecting Right: A regulatory permit issued by the South African Department of 

Mineral Resources and Energy, allowing individuals and companies to explore for 

minerals in South Africa. It is valid for a period of up to 5years and renewable for 

further 3years  

 

Quattro Allocation: This is a scheme designed by the coal mining industry and the 

DMRE to facilitate access to export markets by allocating 4million tonnes of port 

capacity at RBCT for use by emerging and junior coal miners in South Africa 

 

RBCT: Richards Bay Coal Terminal (Proprietary) Limited. It is in Richards Bay 

(KwaZulu Natal Province, South Africa) and is the largest coal export terminal in 

Africa, with an annual design capacity of 91million tonnes 

 

SA: South Africa 

 

SLP: Social and Labour Plan. This is a document that details the mine’s plan to 

contribute to the socio-economic development of surrounding communities in terms of 

the MPRDA (it is a social license to operate, submitted as part of an application for a 

mining right)  

 

WUL: Water Use License. A licence issued by the Department of Water Affairs and 

Sanitation in respect of water uses for certain listed activities at the mine 

 

 

 

 

 

 



 11 

CHAPTER ONE: INTRODUCTION TO THE 
RESEARCH 
 

1.1 Introduction 

South Africa has 53billion tonnes of coal reserves and is ranked number 8 in the world, 

with United States America, Russia and China ranked number 1, 2 and 3 respectively 

(Minerals Council South Africa, 2021). Coal in South Africa is found in 19 coalfields 

(Figure 1), located in KwaZulu Natal (KZN), Mpumalanga, Limpopo, and the Free 

State, with fewer amount in Gauteng, the Northwest Province and the Eastern Cape 

(Jeffrey, 2004). According to (Jeffrey, 2004) the main coal mining areas are Witbank-

Middleburg, Ermelo and Standerton-Secunda areas of Mpumalanga, around Sasolburg-

Vereeniging in the Free State/Gauteng and north-western KZN where smaller 

operations are found. In Ellisras and Tshipise, single, although large operations are 

found (Jeffrey, 2004). 

 

Figure 1: Coalfields of South Africa (Hancox & Götz, 2014). 

 



 12 

The South African coal mining industry produces about 250million tonnes per annum, 

of which about 70million tonnes is exported, 120million tonnes is consumed by Eskom, 

40million tonnes is consumed by Sasol and the rest find its way into the inland market, 

mainly used in boilers and the manufacturing of cement and bricks (Minerals Council 

South Africa, 2021).  The South African coal mining industry is dominated by major 

coal producers, with the top five producers producing more than 80% of the coal in the 

country and has a few mid-tier producers and a handful of junior miners (Hancox & 

Götz, 2014). The top 5 major coal producers in the country are: 

• Exxaro; 

• Seriti Resources, which was formed from the acquisition of former Anglo 

Thermal Coal SA Eskom tied coal mines and the South32 SA Coal Energy 

operations; 

• Sasol Mining; 

• Glencore; and  

• Thungela, formerly known as Anglo Thermal Coal 

 

The ownership and development of minerals in South Africa is governed by the 

Minerals and Petroleum Development Act of 2002 (MPRDA). Prior to 2002, the 

ownership of mineral rights in South Africa was held privately and in some instances by 

the state (Hermanus, Walker, Watson, & Barker, 2015). According to Hermanus, 

Walker, Watson, & Barker (2015), the MPRDA now vests all mineral rights in the state. 

The next section provides background for the South African junior coal mining and its 

context with the South African coal mining sector. 

 

1.2 Background and Context 

1.2.1 The South African junior coal mining sector 

The Junior miners in South Africa are companies that are involved with the exploration 

and production of minerals, with a gross asset value between R18million and R8billion, 

and annual sales of between R30million and R8billion rand (Mitchell, 2016). In 2019, 

the total coal sales in South Africa were just over R140billion and employed just over 

94 000 workers who were paid a total wage of about R30billion (Minerals Council South 

Africa, 2019). This shows that the coal mining sector is a significant contributor to the 

South African economy.  



 13 

The term junior miner, internationally, generally refers to companies involved with 

exploration of minerals, and this is true for countries like Australia and Canada 

(Minerals Council South Africa, 2021). According to Minerals Council South Africa  

(2021), in South Africa, the term junior miner has a broader meaning and includes 

companies across all the stages of the mining project development phases in addition to 

exploration. The main challenges facing this sector are summarised in section 1.2.2, with 

more details in section 2.2. 

      

1.2.2 The challenges and enablers of a sustainable junior coal 
mining sector in SA 

The main challenges facing the South African junior coal miners, along the mining and 

minerals value chain include challenges related to the development of coal mining 

projects, such as availability of good quality coal resources, availability of funding for 

these projects, complying with regulatory requirements, availability of technical skills 

and skilled labour, demands placed by mine host communities on junior mining 

companies, access to markets and availability of logistics and related infrastructures, as 

well as access to the markets.  

 

1.3 Research conceptualisation 

1.3.1 The research problem statement 

The SA junior coal mining sector is fragmented and struggling. This sentiment is 

reflected in the Minerals Council of South Africa 2016 report, which emphasis that the 

sector remains unorganised and have little influence on the country’s mineral policy 

(Mitchell, 2016). The gap between the major and junior coal mining producers in the 

country has been widening in the past decade, with little growth observed in the 

country’s junior coal mining sector. Mining Mx media publication attributes the lack of 

growth of junior coal miners to the current campaign to move away from fossil fuels 

and transition to renewable energy sources like solar and wind (Ryan, 2020). 

 

According to  Mitchell (2016), Kriel (2019), DMRE (2020) and  (Ryan, 2020), the top 4 

main challenges facing the South African junior mining sector are regulatory 

environment, lack of funding, skills and human capital as well as strategic matters such 

as partnering and organising the sector to speak with one voice.  The SA junior coal 



 14 

mining sector was one of the particpants in these prior studies by Mitchell (2016), Kriel 

(2020) and observations by the DMRE (2020) and  (Ryan, 2020). 

 

SA experienced a decline in coal sales for two consecutive years, with sales decreasing 

from R141bilion in 2019, to R131billion in 2020 (Minerals Council South Africa, 2021). 

Despite this, SA coal mining industry remains one of the important contributors to the 

country’s economy, employing about 92 000 employees, earning R31billion in wages in 

2020 (Minerals Council South Africa, 2021). The SA junior coal mining sector forms a 

critical part of SA’s coal mining industry, as it forms a base of the coal mining industry. 

On that basis, the challenges facing the SA junior coal mining sector cannot be left 

unchallenged, as they pose a risk to this sector that contribute significantly to the 

broader SA mining industry and the economy of the country. This statement is 

supported by Kriel (2019)’s analysis of 17 junior miners listed on the Johannesburg 

Securities Exchange (JSE), which indicated that the trading of shares of 41% of these 

junior miners were suspended, implying that some of them were experiencing financial 

difficulty, and on the brink of closing down and retrenching their employees. Therefore, 

the problem statement is the misunderstanding of underlying root causes of the 

persistent challenges that are threatening the sustainability of the SA junior coal mining 

sector. 

 

1.3.2 The research purpose (aim and objectives) statement 

The purpose of this research is to use the qualitative research methods to investigate the 

challenges facing the South African junior coal mining sector. The main aim of this 

research is as follows: 

Aim: To understand the deep underlying issues that contribute to the challenges facing 

this sector, as well as the key enablers for a strong, thriving and sustainable junior coal 

mining sector in SA.  

The objectives of this research include: 

Objective 1: To understand the main challenges facing the SA junior coal mining 

sector; 

Objective 2: To understand the key enablers for a strong, thriving and sustainable 

junior coal mining sector in SA; and 

Objective 3: To produce a roadmap towards establishment of a sustainable junior coal 

mining sector in SA. 



 15 

 

The above three objectives are expanded further in section 1.3.3 as research questions 

and associated propositions. The research will establish the deep underlying root causes 

of the persistent challenges facing the SA junior coal mining sector, further add a new 

body of knowledge in establishing the key enablers of a sustainable junior coal mining 

sector and provide a clear path to transition from the current undesirable state. A 

sustainable junior coal mining sector can positively contribute to a growing SA coal 

mining industry, which can contribute more to the economy and assist in addressing the 

triple challenges of high unemployment rate, poverty and inequality in the country. 

 

1.3.3 The research questions and propositions  

The research questions are structured in such a way that, answering the research 

questions in 1.3.3, assists in achieving the three research objectives stated in Section 

1.3.2 above. From the challenges facing the junior miners as highlighted by Kriel (2019), 

the top two challenges were the lack of enabling regulatory environment and the lack of 

access to funding. Mining is a cyclical business, and as the trading environment changes, 

one would expect the challenges to change, so the research question 1 focuses on the 

main challenges and their underlying root causes, and the research question 2 focusses 

on the key enablers of a sustainable sector in SA. The research questions 1 and 2, are 

related to research objectives 1 & 2 respectively, with research question 3, relating to 

research objective 3 which focus on establishing a road map towards a sustainable junior 

coal mining sector in SA.  

 

1.3.3.1 Question 1: What are the main challenges facing the SA junior coal 
mining sector, as well as their underlying root causes? 

 

Proposition: Eliminate the root causes of the challenges facing the junior coal 

miners to build a strong and sustainable junior mining sector. 

 

1.3.3.2 Question 2: What are the key enablers of a strong, thriving and 
sustainable junior coal mining sector in SA? 

 

Proposition: Good quality, accessible coal resources, transparent and efficient 

mineral regulation administrative processes, enabling mineral policy, access to 



 16 

funding, availability of necessary skills, well developed and logistics 

infrastructure and accessible coal markets are some of the key enablers of a 

sustainable junior coal mining sector. 

 

1.3.3.3 Question 3: What is the potential of SA junior coal mining sector, and 
what does it take to reach this potential? 

 

Proposition: All the key stakeholders in coal mining value chain should 

acknowledge the changes facing the sector and agree to cooperate and work 

together to address the challenges.  

 

1.4 Delimitations and assumptions of the research 
study 

SA is endowed with minerals and has well developed mining industry, made up of 

different sectors such as deep level gold mining, Platinum Group Metals, Ferrous 

Metals, Base Metals, Mineral Sands, Precious Stones (Diamond), Industrial Minerals and 

others. This study is limited in that it focussed primarily on the junior coal mining 

sector, with little peer reviewed literature available on this subject in South Africa. Most 

of the available literature is in a form of reports by industry bodies, experts and the 

regulator. 

 

The study was carried out during the Covid-19 period, as well as at the period of the 

Russian and Ukrainian war, which impacted the logistics for bulk commodities and 

global energy markets. The world campaign on just energy transition, which advocates 

for ceasing of using fossil fuels like coal and replace them with renewable energy 

sources like solar and wind was at its peak during the period of this study. All these 

developments and trends could have influenced the market forces of supply and 

demand for coal and might have had an impact on the SA junior coal miners, and 

somehow exacerbated some of the challenges facing the sector. A perfect example was 

the unavailability of trains to evacuate more product to the export market to benefit 

from the high export coal prices caused by the imbalance of supply and demand forces 

as results of the war in Russia and Ukraine.  

 



 17 

1.5 Significance of the research study 

Section 1.3 showed that the South African junior coal mining sector is a significant 

contributor to the economy. Although the previous studies have identified the main 

challenges facing the sector, they have not established the underlying root causes facing 

the sector. This research is significant as it identifies the underlying root cause for an 

unsustainable junior coal mining sector, the key enablers of a thriving and sustainable 

junior coal mining sector and crafts a path that will assist this sector to reach its 

potential and create jobs and business opportunities to assist the country to reduce the 

triple wicked problems of poverty, inequality and unemployment. The South African 

junior mining sector employs between 33 500 and 40 300 people (Kriel, 2019). The 

results of this study will be used by emerging and aspiring junior coal miners to 

understand the impediments of business development and growth in this sector, 

investors to correctly price their risks when investing in junior coal mining sector, host 

communities and other key stakeholders to understand the challenges and what can they 

do to land a hand, as well as the regulators, academics and policy makers in developing 

mining policies that enable investments and sustainability of the junior coal mining 

sector is South Africa. 

 

1.6 Preface to the research report 

The report is made up of six chapters. The introductory chapter provides a background 

of junior coal mining sector in the context of the South African coal mining industry 

and its contribution to the country’s economy, the research problem statement, the 

research purpose statement which outlines the aim and purpose of the research as 

detailed in the research questions and objectives. The introductory chapter also include 

the delimitations as well as the significance of the research study and is followed by 

Chapter 2, that provides a literature review on the problem, the historical studies, the 

explanatory and the conceptual framework for interpreting the research findings. It then 

summarises and concludes the literature reviewed, and proposes the research strategy, 

design, procedure and methods arising from the literature reviewed. Chapter 3 discusses 

the research strategy, design, procedures, reliability and validity measures as well as 

limitations. Chapter 4 and Chapter 5 presents and discusses the findings respectively, to 

interrogating the research questions and Chapter 6 summarises and concludes the 

research. 



 18 

CHAPTER TWO: LITERATURE REVIEW 

 

2.1 Introduction 

Chapter 1 provided contextual background on South African coal mining industry, the 

junior coal mining sector and introduction to the research. This chapter consists of 

three main objectives; namely to understand the research problem, identify the 

knowledge gap, and develop a framework for interpreting the research findings. The 

research problem is detailed in Section 2.2. In Section 2.3, the literature on studies that 

have attempted a similar study or research is reviewed. With information arising from 

Section 2.3, the qualitative attributes that are key to this research in Section 2.4 as well as 

a framework that will be used to interpret the research findings in Section 2.5 are 

identified and explained in detail. 

 

2.2 The challenges facing the SA junior coal mining 
sector  

 
In the research problem analysis section, the challenges facing the South African junior 

coal mining sector, along the mining and minerals value chain are being studied and 

analysed. The development of coal mining projects commences with the interested party 

compiling a prospecting work programme in preparation to apply for a prospecting 

right (South African Department of Minerals and Energy, 2022). A prospecting right is a 

license that provides one with permission to prospect for a mineral, in this instance the 

mineral being coal. According to the South African Department of Minerals and Energy 

(2022), the prospecting activities include drilling of exploration boreholes and trenching 

to establish the presence of a mineral of economic interest. A prospecting licence is 

valid for a period of five years and can be further renewed for a maximum period of 

three years (Republic of South Africa, 2002).  

 

Once the prospecting activities are completed, and the interested party has established 

that there is enough coal on the ground, then the next step is to conduct the technical 

and commercial studies to determine the technical feasibility and commercial viability of 

the project. A positive outcome then means the project is economically viable, and the 

next step is for the interested party to apply for a mining right. The approval of a mining 



 19 

right application by the Department of Mineral Resources and Energy (DMRE), 

provides the applicant with permission to mine the coal. Both the prospecting and 

mining rights applications are adjudicated by the DMRE and there are other regulatory 

permits that one needs to apply for before the mining right is granted by the DMRE 

(South African Department of Minerals and Energy, 2022). These additional 

applications include the Environmental Authorisation (EA), Water Use License (WUL) 

as well as waste management license if one plans to beneficiate the coal on site (South 

African Department of Minerals and Energy, 2022). Once all this is completed, the next 

step is to raise necessary funding, either from the commercial banks or developmental 

finance institutions and interested investors to fund the development of the mine. Once 

enough funds have been raised, then the coal project is constructed and commissioned 

into a fully operational mine. 

 

The South African junior coal mining sector is fragmented, stagnant and unsustainable. 

Compared to the major coal producers in the country, the junior coal mining sector 

remains unorganised, and the companies involved in this sector have little influence on 

the country’s mineral policy (Mitchell, 2016). The literature review shows that the 

Minerals Council South Africa (MINCOSA) has conducted two studies on this matter, 

one inhouse in 2016 and the second one employing the services of an independent 

consultant in 2019. In addition to this, MINCOSA release annual publication, covering 

all the different mining commodities in the SA mining industry. Other available 

literature is from articles by mining journalists, as well as reports by the DMRE, which is 

a government department responsible for regulating South Africa’s mineral resources. 

The outcomes of the research by MINCOSA, which was conducted by Mitchell (2016) 

and Kriel (2019), as well as other available literature, highlighting the challenges facing 

the South African junior coal mining sector are detailed in the next paragraphs. 

 

The lack of mineral policy enabling investments in mining, the lack of access to funding, 

the dominance of the sector by few major producers and the lack of exploration for new 

coal deposits are attributed as the main challenges that lead to the current stagnant and 

unsustainable status of South Africa’s junior coal mining sector  by Mitchell (2016), 

Kriel (2019), Department of Minerals and Energy (2020) and Ryan (2020) and are 

detailed below.  

 



 20 

2.2.1 The lack of enabling mineral policy 

(Mitchell, 2016), (Kriel, 2019) and (Minerals Council of South Africa, 2019) all believe 

that the lack of mineral policy enabling investments in mining is the sole underlying root 

cause of the status of SA junior coal mining sector. The Department of Mineral 

Resources and Energy (2020) agrees with Mitchell (2016) and Kriel (2019), however, the 

Department of Mineral Resources and Energy (2020) is also of the firm view that 

mineral policy cannot be the sole cause of the status of SA junior coal mining sector.  

 

The DMRE, acknowledges that there are challenges with regards to licensing 

turnaround times and environmental compliance requirements. The department has also 

identified community activism as a challenge to the industry, and on that basis has 

established a new directorate that deals with communities and stakeholder engagements 

(Department of Minerals and Energy, 2020). The agreements and differences between 

the different reports about the underlying causes of the current unsustainable status of 

SA junior coal mining sector are acknowledged by this study, and the author believes 

that a strong mineral policy, should be able to withstand the changes taking place in the 

economy, both locally and globally. 

 

The lack of transparent and efficient mineral regulation and administrative processes, 

results in long lead time to obtain regulatory permits, which leads to an unintended 

consequence of long lead time to develop mining projects. This remains a major 

chalenge in SA junior mining space (Department of Mineral Resources and Energy, 

2020) and SA junior miners cannot afford this as they rely on external funding for their 

mining pojects. Most junior miners have highlighted that they have often lost funding 

that was secured to start a coal project, mainly due to waiting for prolonged period for 

regulatory permits to be approved (Mitchell, 2016). In the study by Kriel (2019), the 

South African junior miners who participated in the study highlighted “uncertain mining 

regulatory enviornment” as an impediment to attracting investment into the junior 

mining sector as shown in Figure 2. 

 

2.2.2 The lack of access to funding  

The lack of access to funding is a major obstacle in promoting junior mining in South 

Africa (Mitchell, 2016). According to Mitchell (2016), this is attributed to the risk averse 

South African commercial banks, that have stringent requirements for funding, such as 



 21 

completed bankable feasibility studies, proven reserves with credible geological studies 

and most junior miners do not have financial resources to take mining projects from 

exploration to bankable feasibility phase. According to Mitchell (2016), even the 

developmental funding institutions like the Industrial Development Corporation (IDC) 

has similar requirements as the commercial banks. The findings by Mitchell (2016), were 

also confirmed by Kriel (2019), who highlighted that the South African commercial 

banks have steered clear of junior miners and sometimes refuse to engage with the 

junior miners on matters of funding their projects. The study by Kriel (2019) highlighted 

that private equity is willing to fund junior miners, however, junior miners do not prefer 

this funding approach as private equity firms tend to dominate the junior miners and 

wants more equity from the junior miners’ mining projects. (Ryan, 2020) strongly 

believes that the world’s move away from coal to renewable energy sources, led to more 

institutions ceasing the funding of new coal projects and coal fired power plants which 

contributes immensely to the lack of access to funding in the junior coal mining sector. 

The perceived impediments to attracting investments into the mining industry are 

summarised in Figure 2  according to the study by Kriel (2019).  

 

 

Figure 2: Junior miners perceived impediments to attracting investment into mining industry 

(Kriel, 2019) 

 



 22 

2.2.3 The dominance of the sector by few major producers   

Few major coal producers dominate the SA coal mining industry, with 80% of the 

country’s coal production being produced by about five companies. The current port 

capacity at the Richards Bay Coal Terminal (RBCT) is about 91million tonnes per 

annum (rbct, 2020), however, the rail capacity is about 70million tonnes per annum 

(Minerals Council of South Africa, 2019). Although the rail capacity does not match the 

port capacity, the major coal producers have access to this infrastructure, which is not 

the case for junior coal producers, who have access to a small portion of this 

infrastructure and this end up limiting the junior coal miners’ access to the export 

market, which then result in a negative impact on their revenue generating capabilities.  

 

The dominance of SA coal mining sector by few large players also distorts the labour 

markets, as most junior coal miners cannot afford to pay market related salaries and 

provide the same working conditions as the large coal producers. Retaining superior 

quality, experienced skills is a huge cost for junior coal miners, and they often rely on 

the services of independent consultants to keep their operations running (Mitchell, 

2016). According to Mitchell (2016), there is very little collaboration between the major 

mining companies and junior miners in South Africa, which is supported by lack of 

support shown by major producers when MINCOSA invited them to share the 

portfolio of their non-core assets and make them available to the junior miners, only 

one out the seven major mining companies responded to MINCOSA’s request. 

 

2.2.4 The lack of exploration for new coal deposits 

“In 2017, South Africa accounted for 1% of the total global exploration expenditure 

with 14% for Canada, 14% for Australia and 13% for the rest of Africa. South Africa's 

share of African exploration budget was 8.3% in 2017 compared to 20% in the year 

2000” (Department of Minerals and Energy, 2020). The lack of exploration for new 

mining resources was also highlighted by Mitchell (2016).  Mitchell (2016) attributed the 

lack of exploration in South Africa to lack of suitable financial vehicles and models to 

stimulate exploration and likened exploration to research in manufacturing, emphsising 

that lack of exploration has a potential to collapse the whole mining industry. According 

to Mitchell (2016), the geological endowment is a pre-requisite for funding by 

commercial banks in South Africa, and this remain one of the  challenges facing the 

junior miners in this country. 



 23 

 

The consequences and the root causes of unsustainable junior coal mining sector in SA, 

using the Norwegian Agency for Development Co-operation  (NORAD) problem tree 

analysis  (NORAD, 1999) are summarised in Figure 3. As indicated in Figure 3, the 

underlying causes of the challenges facing the junior coal mining sector in SA, stems 

from the lack of a mineral policy that enables investments in mining. The consequences 

of these challenges then manifest in a form of under-capitalised mining operations, 

revenue losses, disruption of operations by endless community protests as well as junior 

coal miners’ inability to attract and retain top talent and skills in the industry. The 

combination of these then lead to higher inputs costs of mining, which then results in 

unprofitable operations. Unprofitable operations limit the ability of junior coal miners 

to reinvest cash to grow their businesses. It also impact their capital raising capabilities, 

leading to a limited growth and a stagnant junior coal mining sector. According to 

Brendan Ryan (2020), the future of the South African coal mining industry appears 

bleak, and this trend has been observed for a while. 

 

 



 24 

Unsustainable junior coal mining sector in South Africa

PROBLEM TREE ANALYSIS (ACCORDING TO NORAD, 1999)

Lack of enabling 
mineral policy

Lack of 
investment in 

exploration

Unavailability of 
good quality coal 

resources

Lack of 
investment in 
infrastructure

Lack of access to 
markets

Lack of 
transparent & 

efficient mineral 
regulation 

administrative 

Move to 
renewable 

energy projects

Domestic market 
dominated by 
few large scale 

coal miners

Stringent
environmental 
laws (climate 

change)

No access to 
funding for coal 

projects

Under capitalised 
mining projects

Unscalable 
mining 

operations

Long lead time to 
develop mining 

projects

Long lead time to 
obtain regulatory 

permits

Higher mining 
costs

Higher mining 
costs

Unprofitable
mining 

operations

Limited growth 
Stagnant junior 

coal mining 
sector

No enonomies of 
scale

Revenue loss

Coal production 
dominated by 

few large / major 
coal miners

Measure: number of listed 
junior coal miners active in 
SA 

Unsustainable junior coal mining sector in South Africa

Pay market 
related salaries 

for labour

Unafordability of 
skilled labour by 

junior miners

High costs of 
skilled labour

Disruption of 
operations by 

community protests

Need additional 
resources to manage 
community protests

Impoverished 
mining 

communities

Fe
ed

ba
ck

 

Figure 3: Problem tree analysis of challenges facing SA junior coal mining sector 



 25 

 

2.3 Research knowledge gap analysis 

This section reviews the available literature, studies and reports on the challenges facing 

the SA junior coal mining sector, as well as their underlying root cause. This is carried 

out to understand the knowledge gap with regards to the challenges facing the sector, as 

well as the underlying causes. This is achieved through analysing similarities and 

differences in the existing literature on challenges facing the SA junior coal mining 

sector and finding out why these challenges are still persistent, and the sector is 

remaining unsustainable. 

 

Mitchell (2016) undertook a study to understand the challenges facing the emerging and 

junior miners in South Africa, supported by the empirical evidence in a form of industry 

reports on junior mining sector, documented workshops, conducted by the MINCOSA, 

seminars and evidence from engaging with the industry experts. Mitchell (2016)’s study 

was commissioned and funded by the MINCOSA, with an aim to sensitise the DMRE, 

government and major coal mining companies of the plight of junior miners in SA. 

 

In 2018, the MINCOSA commissioned Hermanus Kriel, to undertake a study to 

determine the “extent, nature and economic impact of the junior and emerging mining sector in South 

Africa” (Kriel, 2019). The study was a continuation of the work conducted by Mitchell in 

2016, and it included conducting literature review, as well as a survey using the junior 

miners in a database from the MINCOSA Junior and Emerging Miners Desk as a 

sample for the survey. The study by Kriel (2019), confirmed the challenges facing the 

South African junior mining sector identified by Mitchell (2016), which include the lack 

of enabling mineral policy, the lack of access to funding, dominance of the sector by few 

major companies and lack of exploration for new resources.  

 

In 2020, Brendan Ryan published an article within the Mining Mx mining yearbook, 

titled “future of SA coal is not what is used to be” (Ryan, 2020). Ryan (2020) highlighted the 

impact of a move towards renewable energy sources on the SA coal mining industry, 

which indirectly affect the junior coal miners who are already struggling due to lack of 

access to funding, lack of access to markets, and high mining input costs. There were no 

limitations documented by both  (Mitchell, 2016) and  (Kriel, 2019) in their research. 

However, the author’s assessment of Mitchell and Kriel’s studies is that Mitchell’s study 



 26 

relied heavily on his past work around this subject, and did not engage other key 

stakeholders such as the DMRE to understand their percepective on the challenges 

facing the South African junior miners as the regulator in the industry.  

 

The limitation to Kriel’s study is that the sample size of the survey was based only on 25 

junior miners who were in the database of the MINCOSA’s Emerging and Junior 

Miners Desk, and was not extended to other junior miners who are not part of the 

MINCOSA database. A survey was conducted as part of Kriel’s study. This survey was 

more prescriptive and had no open ended questions to allow the junior miners to state 

some of the challenges in addition to those that were already listed on the survey. The 

South African mining industry is broad, and some of the challenges faced by the 

different sectors are unique to that mining sector, and Kriel’s study (2019) did not show 

the challenges by the different junior mining sectors, for example, coal, iron ore, 

chrome, gold and platinum group metals and others. 

 

From the problem research analysis, the literature indicate that the challenges facing the 

South African junior coal mining sector highlighted by Mitchell (2016) and Kriel (2019), 

could be traced back to one root cause, which is the lack of mineral policy that enables 

investment in mining in South Africa. However, as indicated above, the studies were 

limited only to junior miners affliated to MINCOSA emerging and junior miners desk, 

were more presceiptive and did not allow the junior miners the freedom to raise the 

challenges that might be unique to their sectors or common challenges that need 

fundamental shift in the country’s mineral policy. The studies also only focussed on the 

challenges, and not the enablers of the junior mining sector. 

 

On that basis, this study will build on the existing research by involving all the junior 

miners along the mining and mineral value chain in coal, and provide them with a 

platform to raise the challenges as they experienced them and not limit them to select 

from a pre-determined list of perceived challenges. The regulator in the form of the 

DMRE and MINCOSA will also be provided with an opportunity to raise the 

challenges facing this sector as they understand them. The study will explore some of 

the components of the South African mineral policy that have been highlighted by 

Mitchel (2016), Kriel (2019) studies, the DMRE and some of the junior miners in detail. 

The understanding of the challenges facing the SA junior coal mining sector, their 



 27 

underlying root causes as experienced and understood by the junior coal mining sector 

as well the key enablers of a sustainable sector remain a knowledge gap and this will be 

explored in detail by this research study.   

 

2.4 Qualitative attributes key to the research 

When carrying out the research knowledge gap analysis, similar research studies in 

literature show the research strategy, research design, research procedure and methods 

used, including the information collected and analysed. 

 

The first qualitative attribute key to this research is the challenges facing the South 

African junior coal mining sector as indicated by the research problem analysis. The 

research used the challenges facing the sector highlighted in the literature by Mitchell 

(2016) and Kriel (2019). These include the lack of enabling mineral policy, the lack of 

access to funding, the dominance of the sector by few major companies and lack of 

exploration for new resources.  An in-depth analysis of these challenges indicates that 

the lack of enabling mineral policy is not only a challenge facing the sector, but it is also 

an underlying root cause for the other challenges facing the sector.  

 

The second qualitative attributes, which are not covered in the literature review, include 

the key enablers of a sustainable junior coal mining sector, and the final qualitative 

attribute that pursued by this research is the roadmap towards a sustainable junior coal 

mining sector in South Africa. 

 

This research pursued the qualitative attributes listed above to answer the research 

questions in Section 1.3.3. The first qualitative attribute was pursued to answer research 

question 1, “What are the main challenges facing the South African junior coal mining 

sector, as well as their underlying root causes”? and used to prove the research 

proposition 1, “the root causes of the challenges facing the junior coal miners should be 

eliminated to build a strong and sustainable junior mining sector”.  

 

The second qualitative attribute answered the research question 2, “what are the key 

enablers of a strong, thriving and sustainable junior coal mining sector in SA”? and used 

to prove the research proposition 2, “good quality, accessible coal resources; transparent 

and efficient mineral regulation administrative processes; enabling mineral policy; access 



 28 

to funding, availability of necessary skills, well developed and logistics infrastructure and 

accessible coal markets are some of the key enablers of a sustainable junior coal mining 

sector”.   

 

The final qualitative attribute was pursued to answer the research question 3, “What is 

the potential of SA junior coal mining sector, and what does it take to reach this 

potential”? and used to prove the research proposition, “all the key stakeholders in coal 

mining value chain should acknowledge the changes facing the sector and agree to 

cooperate and work together to address the challenges”. 

 

The underlying root causes of the challenges facing the sector were identified and 

understood, to pave the way for enablers towards a sustainable sector and a roadmap 

that needs to be followed to assist the South African junior coal mining sector to pivot 

from the current undesirable status towards sustainability. The information for the 

qualitative attributes for this research was collected through interviews with the owners 

and executives on junior coal mining companies, the DMRE and MINCOSA. 

 

 

2.5 Frameworks for interpreting research findings   

The review and interrogation of literature on challenges facing the SA junior coal 

mining sector, as well existing qualitative research allows for identification of existing 

and well-established frameworks utilised to analyse and interpret the research findings. 

In this section, the research findings on the challenges facing the South African junior 

coal mining sector, as well as the key enablers of a strong and thriving junior coal 

mining sector are being interpreted. The interpretation of these findings will assist with 

understanding the root causes and recommending the measures that will ensure a strong 

and thriving junior coal mining sector in South Africa. This is achieved through using 

established frameworks for interpreting the findings of a research of this nature.  

 

2.6 Summary and conclusion 

2.6.1 Summary of literature reviewed 

The literature reviewed indicated that the South African junior coal mining sector is a 

critical sector within the South African coal mining industry. The literature also 

confirmed that there are challenges facing the sector. These challenges have different 



 29 

underlying causes, and a stagnant and unsustainable junior coal mining sector is just a 

symptom of these challenges. An in-depth analysis of these underlying causes showed 

that they stem from a root cause, which is the lack of an enabling mineral policy. 

 

The literature review also showed that, the consequences of these challenges, manifest 

in a form of under-capitalised mining operations, revenue losses which affect the 

profitability of the operations, community protest, long lead time to develop projects as 

well as high input costs of mining.  

 

Mitchell (2016), Kriel (2019) and Ryan (2020) agree on the challenges facing the sector, 

although Ryan (2020) highlighted the campaign to move away from coal generated 

power to renewable energy as a serious concern to the coal mining industry at large. The 

DMRE does not believe that mineral policy alone can eliminate all the challenges facing 

the junior miners, however, the department acknowledges that there are challenges 

related to mineral policy and such challenges, for example, long turnaround times 

related to permitting and licensing are being addressed as a matter of priority 

(Department of Minerals and Energy, 2020). The knowledge gap analysis showed that 

there’s research work that needs to be done around mineral policy in SA, to prove its 

real impact on the sustainability of junior miners in South Africa. 

 

2.6.2 Proposed research strategy, design, procedure and methods 
arising from the literature reviewed  

The studies reviewed in literature showed the research strategy, research design, research 

procedure and research methods used, including detailing the information collected and 

analysed as part of the study. The first qualitative attribute is the challenges facing the 

South African junior coal mining sector in the context of South African mining industry, 

which has coal mining, precious metals (gold and platinum group metals), ferrous 

metals, industrial minerals and others like clay and aggregates. The second qualitative 

attribute is the key enablers of a sustainable junior coal mining sector, and the final 

qualitative attribute is the roadmap towards a sustainable junior coal mining sector in 

South Africa, which paves the way for closing the gap between the status of the South 

African junior coal mining sector and where it supposes to be in terms of its potential. 

 



 30 

The interrogation of earlier literature by other researchers on the challenges facing the 

South African junior mining sector, as well as analysis of multiple challenges that results 

in more undesirable effects has helped in identifying the existing established frameworks 

used in research for this study. The NORAD problem tree analysis interpretive 

framework was used in finding the root cause of multiple undesirable effects, which are 

often the symptoms of a deep underlying problem. If the deep underlying problem is 

not accurately diagnosed, the proposed solution ends up only addressing the undesirable 

effects, leaving the deep underlying problem untreated. 

 

The use of the NORAD problem tree analysis method was not common in the 

literature reviewed on the challenges facing the South African junior mining industry. 

This study focusses on the main challenges and key enablers of a sustainable junior coal 

mining sector in South Africa, hence it appeared proper to use the NORAD problem 

tree analysis to understand the root cause of the challenges facing the South African 

junior mining sector as highlighted in the established literature. The existing literature 

mostly focussed on the challenges facing the South African junior coal mining sector, 

and little on the key enablers and a roadmap towards a sustainable junior mining sector.  

 

The earlier studies used workshops, surveys, were more prescriptive when collecting the 

data on the challenges facing the sector and left no room for the sector to raise any 

challenges that it was experiencing. The questions about the root causes and key 

enablers of a sustainable sector were not included in the survey, and to overcome this 

shortcoming, this study used face to face, as well as telephonic interviews with open 

ended questions to collect the information from the sector, and more details on the 

research strategy, procedures and methods used are detailed in Chapter 3. 

 

 

 

 



 31 

CHAPTER THREE: RESEARCH STRATEGY, DESIGN, 
PROCEDURE AND METHODS 
 

3.1 Introduction 

Research strategy refers to a way research is conducted (Bryman, 2012). Based on the 

literature reviewed, the qualitative research strategy was proposed for this study. 

Research design provides a structure of how research will be carried out. It provides the 

blueprint of how the data will be collected and processed. There are five generic 

research designs, namely: experimental, cross-sectional, longitudinal, case study and 

comparative (Bryman, 2012). The longitudinal research design was proposed for this 

study. 

 

The research procedure and methods are about the actual procedure and the methods 

employed in research to collect, collate, process, and analyse empirical evidence. The 

research data collection instrument is an instrument designed to extract the data that will 

be needed for analysis to complete the research work (Babbie, 2013). Based on the 

literature reviewed, the proposed instrument for this research is the interview schedule 

research data collection. 

 

The target population is made up of several cases that a research sample maybe be 

derived from (Bryman, 2012). The target population for this study included junior coal 

mining companies with active coal mining projects at various development stages, as 

well as operating mines in South Africa. It also includes key stakeholders like the 

industry body in the form MINCOSA and the regulator in a form of the DMRE. 

Utilising this target population was of great benefit to this study as the participants are at 

the coal face of the challenges facing the sector, and the researcher has well established 

access to the majority of the target population 

 

In Section 1.3.3, three questions that this research report intends to answer are posed: 

‘What are the main challenges facing the SA junior coal mining sector, as well as their 

underlying root causes?’, ‘What are the key enablers of a strong, thriving and sustainable 

junior coal mining sector in SA?’, and ‘What is the potential of SA junior coal mining 

sector, and what does it take to reach this potential?’  The literature has been reviewed 

and an interpretative as well as a conceptual framework developed. These guided the 



 32 

choices of techniques used. Chapter 3 identifies and describes the research approach, 

design as well as a procedure and methods employed in this research to collect, process, 

and analyse empirical evidence. Broadly, it has three objectives; namely, to identify and 

describe the research strategy (Section 3.2), the research design (Section 3.3), as well as 

the procedure and methods (Section 3.4). Chapter 3 also describes the reliability and 

validity measures (Section 3.5) that this research applies to make it credible as well as the 

technical and administrative limitations of the choices made (Section 3.6). 

 

3.2 Research strategy 

Research strategy refers to a way research is conducted (Bryman, 2012). There are three 

types of research strategies, namely: qualitative, quantitative and mixed research strategy. 

In this study, the literature review shows that the lack of mineral policy that enables 

investments in the South African mining industry is at the core of challenges facing this 

sector. The challenges facing this sector are well documented, and the knowledge gap 

analysis shows that the focus area for this research should be on SA mineral policy, 

concentrating more on the components of the policy that have been flagged by the 

DMRE and some of the junior coal miners in the country.  

 

For purpose of this research, the data was sourced and obtained through studying 

existing literature, observations and conducting interviews with different key role players 

in the South African junior coal mining sector. The identified key role players include 

junior coal mine producers, service providers, relevant government departments like the 

DMRE, and end users of coal in SA. In summary, qualitative research strategy was 

adopted for this study. 

 

In 2016, Grant Mitchell adopted a qualitative research strategy in conducting a similar 

study commissioned by MINCOSA, which was then called the South African Chamber 

of Mines. The main aim and objective of Mitchell’s study was to unpack the existing 

knowledge about the South African junior mining sector and explain the main 

challenges facing the sector. Mitchell’s research was supported by empirical evidence 

based on reports on the sector, workshops and seminars and interviews from the 

industry experts. 

 



 33 

 Mitchell adopted a qualitative research strategy to achieve the main aim and objective of 

his research, and produced practical challenges and solutions, with inputs from the role 

players, which could be taken back to the same industry for consideration and 

implementation by the role players and regulatory bodies. The aim of Mitchell’s study 

was achieved and led to a second study which was commissioned in 2019, to conduct 

further research on the knowledge gap from Mitchell’s 2016 study. The 2019 study was 

conducted by Hermanus Kriel on behalf of MINCOSA. 

 

Qualitative research strategy was beneficial for this research on the challenges facing the 

South African junior coal mining sector, as it offered an opportunity to develop specific 

insights about the industry, and it does not require a large sample size in collecting the 

relevant data about the sector, as key role stakeholders were interviewed as part of data 

collection. 

 

3.3 Research design 

Research design provides a structure of how research will be carried out. It provides the 

blueprint of how the data will be collected and processed. Different components of the 

research process need to be taken into consideration when designing a study. These 

include among others, the main aim and objectives of the study. There are five generic 

research designs, namely: experimental, cross-sectional, longitudinal, case study and 

comparative (Bryman, 2012).  

 

This study used a longitudinal research design. This design entails qualitative content 

analysis of literature relating to different periods and interviewing on more than one 

occasion (Bryman, 2012). Conducting interviews as part of research process is one of 

the benefits of using longitudenal research design, and this is used in this study. 

Longitudenal research design has been used in prior studies on junior coal mining sector 

in South Africa as indicated below. 

 

(Mitchell, 2016) undertook a study to examine the challenges facing the junior mining 

sector in South Africa. Mitchell’s study focused on junior mining sector across all 

commodities, and its objective was to review the existing knowledge about the emerging 

and junior mining sector in South Africa. The rational behind using longitudenal 

research design was to ensure that Mitchell is able to rely on his and the experience of 



 34 

other experts in the sector, as well as the well documented content from the variuos 

workshops and interviews about the sector. 

 

Utilising the longitudenal research design was beneficial to this research as existing 

literature on junior mining sector in South Africa was reviewed, and in-depth interviews 

were conducted with the key role players in the sector to understand the challenges 

facing the sector, their root causes and the path that can be followed to establish a 

sustainable junior coal mining sector in the country. 

 

3.4 Research procedure and methods 

The research procedure and methods are about the actual procedure and the methods 

employed in research to collect, collate, process, and analyse the resultant data (Bryman, 

2012). The research data collection instrument is an instrument designed to extract the 

data that will be needed for analysis to complete the research work (Babbie, 2013). 

According to Neuman (2014), the research methods have techniques that are used in a 

study to gather and process data and report on the findings. 

 

This section of the research documented the actual procedure and methods employed in 

this research to collect, collate, process, and analyse empirical evidence as outlined by 

Neuman (2014). Broadly, the data and information collection instruments (Section 3.4.1) 

are detailed, the target population and sampling of respondents (Section 3.4.2), the 

ethical considerations during the research process (Section 3.4.3), data and information 

collection process and storage (Section 3.4.4), data and information processing and 

analysis (Section 3.4.5) as well as the background description of the respondents who 

provided empirical evidence for this research study (Section 3.4.6). 

 

3.4.1 Research data and information collection instrument(s) 

Research data collection instrument is an instrument designed to extract data needed for 

analysis to complete the research work (Babbie, 2013). In qualitative research, there are 

two types of research data collection instruments, namely: observation schedule and 

interview schedule (Bryman, 2012).  

 



 35 

This research utilised the interview schedule research data collection instrument as it 

provides more flexibility and allows the researcher to obtain deeper meaning on the 

topic (Bryman, 2012).  

 

Qualitative research is less structured compared to quantitative research, and it does not 

limit the researcher in terms of obtaining deeper meaning of the concepts being 

researched from the respondents (Bryman, 2012). According to Bryman (2012), there 

are three types of data collection instrument structures, namely: unstructured, semi-

structured and fully structured. This study used a semi-structured interview schedule 

data collection instrument. A set of questions were prepared and shared with the 

respondent prior to the interview taking place. 

 

The questions were classified into two categories, namely category A and category B. 

The category A questions were the research question 1 “What are the main challenges 

facing the South African junior coal mining sector, as well as their underlying root 

causes”? and the research question 2 “what are the key enablers of a strong, thriving 

sustainable junior coal mining sector in SA”? These questions were treated as broad 

questions and were asked to all the key role players in the junior coal mining sector who 

participated in the interviews. 

 

The category B questions were specific and classified according to the following groups: 

• Companies with projects at exploration phase – three questions were asked, 

relating to how long it took the junior miner to obtain a prospecting right, 

experience of a junior miner on the prospecting right application process and 

interacting with the DMRE and whether the junior miner thinks there is a room 

for improvement when it comes to the DMRE process to grant the prospecting 

rights; 

• Companies with projects at development phase – four questions were asked, 

relating to how long it took the junior miner to obtain the mining right, junior 

miner’s experience on the mining right application process and interacting with 

the DMRE; whether the junior miner thinks there is a room for improvement 

when it comes to the DMRE process to grant the mining rights and find out if 

the other regulatory permits like the environmental authorisation (EA) and the 

water use license (WUL) were granted on time; 



 36 

• Companies with operating mines – three questions were asked, relating to 

what the junior miners think the DMRE can do to reduce the regulatory burden 

on junior miners, what is the most difficult part to junior miners when it comes 

to complying with the conditions attached to their regulatory permits and what 

is working and not working with the current mining legislature, with special 

focus on the MPRDA; 

• The Department of Mineral Resources and Energy (DMRE) – only two 

questions were asked, relating to understanding why the processing of 

applications for regulatory permits takes longer than anticipated, and what is the 

DMRE doing to enable the junior miners from a mineral policy perspective; and 

• The Minerals Council South Africa (MINCOSA) – only two questions were 

posed to MINCOSA, relating to understanding what is MINCOSA as a mineral 

industry body that ensure the industry speaks with one voice, doing to assist the 

struggling junior mining sector from a policy perspective, and does the 

MINCOSA believe that the junior miners should be subjected to the same 

regulatory requirements as the major coal producers? (See Appendix 1.1 for 

more details on the data collection instrument) 

 

 The semi-structured interviews and sharing of questionnaires prior to the interview 

assisted with ensuring that the interview is structured in terms of addressing the research 

questions, and that there’s added flexibility to obtain deeper meaning of the concepts 

during the live interview process. A semi-structured interview data collection has been 

utilised in previous studies as outlined below. 

 

In a similar study commisioned by the Emerging and Junior Miners Desk of the 

Minerals Council of South Africa, (Kriel, 2019) utilised a semi-structured interview data 

collection instrument in investigating the extent, nature and economic impact of the 

emerging and junior mining sector in South Africa. The main objective of this study was 

to provide insights on the junior mining sector in terms of its size, as well as economic 

impact in South Africa. Kriel selected this combination of data collection instrument 

mainly due to the flexibility it provided, and he benefited from applying this approach as 

he was able to establish the size and economic contribution of the sector to South 

Africa, as well as pointing out the challenges facing this sector from the interviews 

conducted with the key role players in the sector.   



 37 

 

3.4.2 Research target population and selection of respondents 

 

3.4.2.1 Research target population 

The target population is made up of several cases that a research sample maybe be 

derived from (Bryman, 2012). The participants in the research are selected based on the 

research focus area. This is critical for enabling the researcher to achieve the aims and 

objectives of the research (Symon & Cassel, 2012). The target population for this study 

included junior coal mining companies with active coal mining projects at various 

development stages, as well as operating mines in South Africa. Prior studies have used 

similar target population as detailed below. 

 

Mitchell (2016) and Kriel (2019)’s studies included similar target populations in their 

studies. The objective of Mitchell’s research was to review the existing knowledge about 

the emerging and junior mining sector in South Africa. Although Mitchell’s target 

population was broader as it cut accross all mining commodities, Mitchell chose this 

target poulation because of its significant contribution to the South African mining 

industry and economy. The benefits of using this target population are evident in how 

Mitchell successfully unpacked insights about this sector, as well as highlighting the 

challenges facing this sector.  

 

Utilising this target population was of great benefit to this study, as the participants were 

accessible despite the notable challenges due to Covid-19, and were willing to share their 

lived experiences, as well as daily challenges and hardships they have to endure to keep 

their business alive.  

 

3.4.2.2 Sampling or selecting respondents from the target population 

Sampling is a process of selecting a group of participants for a purpose of conducting 

research (Wagner, Kawulich, & Garner, 2012). A sample is a small number of cases, 

selected from a large group or pool of cases and analysed as a representative of the 

larger group (Neuman, 2014). There are three concerns when selecting a sample for 

research purposes, namely: assurance that the sample assists the researcher to collect 

appropriate data, usage a relevant sample technique to participants who are suitable for 

the research aim, and lastly, the number of participants or the sample size (Symon & 



 38 

Cassel, 2012). According to Symon and Cassel (2012), the sampling method can be 

based on one of two principles, namely: probability sampling or non-probability 

sampling. 

 

This study will use a non-probability sampling technique. The non-probability sampling 

technique entails a sample that has not been chosen through random selection (Bryman, 

2012). When this sampling technique is used, the selection for suitable participants is 

based on the researcher’s judgement of the characteristics of the population required for 

the data to achieve the aim of the research (Symon & Cassel, 2012) Furthermore, 

participants tend to be involved in the study using non-probability sampling technicque 

because of their availability  and willingness to participate (Wagner, Kawulich, & 

Garner, 2012). The common non-probability sampling techniques are convenience 

sampling (also known as purposive sampling), snowball sampling, and quota sampling 

(Bryman, 2012;  Neuman, 2014). For this study, I am working in the coal mining sector 

and have access to most junior coal miners in South Africa, the DMRE and the industry 

bodies like MINCOSA, hence purposive sampling technique will be used. 

 

This technique has been used in similar prior studies. For example, a study by Kriel 

(2019), which investigated the extent, nature and economic impact of the emerging and 

junior mining sector in South Africa. Kriel (2019) targeted about 25 junior miners, and 

only 68% participated, however Kriel was able to achieve the research objectives as he 

successfully established the size and economic contribution of the sector to South 

Africa, as well as pointing out the challenges facing this sector.  

 

The target population for the proposed research includes junior coal miners that are at 

different project development phases along the mining value chain, MINCOSA, which 

is the industry body which represent most major and junior mining companies in South 

Africa and the regulator in a form of the DMRE. Twelve junior coal miners were 

identified and shortlisted for the study, and only eight participated in the study. 

  

3.4.3 Ethical considerations when collecting research data 

Ethics in research is about behaving and conducting oneself in a morally acceptable way 

when conducting research project. Ethical issues must be considered at every step of the 

research process, from the research strategy, design and implementation (Wagner, 



 39 

Kawulich, & Garner, 2012). This is to ensure that the rights of the subject being studied 

or investigated are respected and protected, as well as those of other participants in the 

research process. Ethics requires the researcher to strike a balance between the rights of 

all participants in the researcher’s pursuit for knowledge to fulfil the research aims and 

objectives. 

 

The researcher for this study is a part time Master of Business Administration (MBA) 

student at the Wits Business School (WBS) and a full-time employee of one of the major 

coal mining companies in South Africa. The researcher’s interest in the study is for 

academic purposes and neither the researcher nor his employer, who is funding the 

MBA studies benefited commercially from this research (see Appendix 2.1 for 

Research’s brief biography). Ethical considerations as highlighted by Bryman (2012) 

were thoroughly observed and complied with as outlined below. 

 

Deception of Respondents: 

The researcher assures the research community that the participants in the proposed 

research were not deceived, and all disclosures related to the researcher and the research 

work were disclosed upfront before engagements on the subject being investigated. 

 

Cause Harm or Stress to the Participants: 

The researcher makes a pledge to the research community that in conducting this 

research, no harm or stress, physically or developmentally were caused to the 

respondents or drive them to a point where they lost their confidence. In addition to 

this, the researcher would like to highlight that this research and its supporting research 

data collection instrument were subjected to WBS Ethics Committee scrutiny and 

obtained ethics clearance before the research work could commence. 

 

Informed Consent to Interview: 

The researcher assures the research community that informed consent was obtained in 

advance, to interview the respondents and if necessary, record them. Participants were 

issued with a consent form which explained to them what the research is about, and that 

participation is on a voluntary basis (See Appendix 2.2). 

 

 



 40 

Protection of Respondents and Data: 

The researcher assures the research community that the respondents were protected. 

Their identity will not be revealed and the data they shared is secured. The data is stored 

electronically and accessible through password protected devices like computers and 

tablets. 

 

3.4.4 Research data and information collection process 

Research data or information collection is a process of collating data or information 

from the research sample to address the research questions (Bryman, 2012). There are 

four modes of research data collection, namely: participant observation, or ethnography, 

interviews (face-to-face, telephone or internet based) (Bryman, 2012). 

 

The face to face, telephone and internet-based interviews were utilised to collect 

information for this study. This was beneficial to this study as it provided a seamless 

access to the target population, given the tight time frames that the researcher was 

working under, as well as the current Covid-19 situation in the country, which 

prohibited coming into contact when not necessary to reduce the probability of 

spreading the Corona virus in the country. Eight out of the twelve identified and 

shortlisted junior coal miners participated in the study. The additional participants were 

the DMRE and MINCOSA, so the total number of participants in this study is ten. 

Four out of eight junior miner interviews were conducted face to face, notes taken, and 

the participants requested not to be recorded. The other four junior miner interviews 

were conducted visually using Microsoft Teams, notes were taken on all of them, and 

only one junior miner agreed to be recorded. The MINCOSA interview was conducted 

through Microsoft Teams, and notes taken. The DMRE interview was conducted face 

to face, notes taken and the representative from the DMRE also opted not to be 

recorded. Prior studies have used similar mode of research data and information 

collection. For example, Mitchell (2016) and Kriel (2019) have used similar mode in 

similar research in the emerging and junior mining sector in South Africa.  

 

3.4.5 Research data and information processing and analysis 

3.4.5.1 Research data and information processing 

Research data processing is a process of extracting information from a collected data. 

Before the information can be extracted from collected data, the following process must 



 41 

be carried out: transcribing, determining themes theoretically or data driven and data 

fragmentation.  

 

Transcribing is a process of transforming the information from audio to text, in 

qualitative research where the information was recorded from an interview. 

Determining themes refers to a process of conceptualising themes from the collected 

data. This can either be based on theory or driven by the collected data. Data 

fragmentation refers to a process of packaging collected data into different themes. 

 

In this study, information was collected through interviews and recorded electronically. 

The recorded information was then transcribed into text, and themes conceptualised 

before being packaged into different themes. 

 

3.4.5.2 Research data and information analysis 

Research data and information analysis is a process of disseminating data and 

information to create meaning from the collected data, to answer the research question 

(Wagner, Kawulich, & Garner, 2012). Narrative analysis and thematic content analysis 

are the common data and information analysis methods in qualitative research. 

Narrative analysis method focusses on how people make sense of events that have 

already taken place, and thematic content method is subjective dissemination of 

information after it was systematically classified into different themes. 

 

This study utilised the thematic content analysis. This was beneficial to this study as 

information was collected through semi-structured data collection instrument and 

classified into different themes before being analysed. Notes were made from face to 

face as well as telephonic interviews where the participants opted not to be recorded. All 

the hand-written notes and information from audio recording were transcribed into an 

excel sheet, stored in an electronic format for further analysis. In excel, the information 

was systematically packaged and classified according to two categories of questions, and 

the different role players in the junior coal mining sector. It was then analysed, to 

identify similarities and differences and repetitions. Prior research in similar research has 

successfully used this analysis method. The most recent ones are the studies by Mitchell 

(2016) and Kriel (2019), who conducted studies in the South African emerging and 

junior mining sector. 



 42 

 

3.4.6 Description of the research respondents 

The following information was collected to authenticate the respondents in the research 

process:  

• The project phase in the mineral value chain (exploration project, development 

project or operating mine),  

• The role of the respondent in the company (director/executive, manager or 

specialist); and  

• Years of experience in the mining industry (less than 20, 20 – 30 and more than 

30 years). See more details on the data collection instrument in Appendix 1.1. 

 

3.5 Research strengthens—reliability and validity 
measures applied 

Reliability in research is a question of whether the study can be replicated to test its 

reliability, and validity in research is more about the integrity and credibility of the 

research process used to complete the study. Reliability and validity are critical to 

determine the quality of research (Bryman, 2012). Research reliability is mostly 

dependent on the detailed description of the research process. The research strategy, 

design procedure and methods for the proposed research are detailed and well defined 

to ensure reliability of this study. 

 

Mitchell (2016) undertook a similar study, reviewing the existing knowledge on the 

emerging and junior mining sector in South Africa, as well as highlighting the challenges 

facing the sector. Mitchell’s research process was well defined, and its reliability was 

tested by Kriel (2019) who replicated Mitchell’s study, but with an added scope of work. 

Kriel (2019) proceeded to make recommendations that Mitchell (2016)’s definition of a 

junior miner should be adopted as a standard definition of a junior miner in South 

Africa. 

 

Kriel (2019) also tested the validity of Mitchell (2016) study as he demonstrated 

dependability on the previous work from Mitchell. The research process for this study is 

well defined and was followed to the teeth to maintain its integrity and credibility. The 



 43 

interviews were recorded where participants gave consent for their interviews to be 

recorded. 

 

3.6 Research weaknesses—technical and 
administrative limitations  

The technical and administrative limitations that were encountered in carrying out this 

research are outlined below:  

 

Technical Limitations:  

• Research data collection instrument – a semi-structured interview schedule 

has been selected – some of the respondents were biased in their response 

(telling the researcher what they think the researcher wants to hear and not 

answering the questions objectively). This was minimised by listening attentively 

and asking for further clarity on answers where necessary. 

• Research target population – the junior mining sector was already struggling 

prior to covid-19 pandemic which led to prolonged lockdown in 2020 and 2021, 

this resulted in a shrinking pool of target population as some of the junior 

miners closed their businesses due to poor economic conditions. This was 

mitigated by targeting all the junior miners who were in operation prior to the 

Covid-19 pandemic. Availability of some of the target population personnel was 

a challenge, as people prioritised struggling mining operations under Covid-19. 

This was mitigated by working according to the availability schedule of the target 

population. The change of leadership at the DMRE national office also posed a 

challenge, and this was mitigated by interviewing a senior DMRE representative 

from a regional office with more coal mining operations in the country. 

• Sampling and selection of respondents – the shrinking pool of target 

population impacted availability of the required sample size. Although this led to 

research not being completed at the researcher’s initial target date, this was 

mitigated by being patient, and ensuring that most of the identified personnel 

are interviewed. 

• Ethical considerations when collecting data – some of the respondents were 

not comfortable in conducting interview with a researcher operating in the same 

sector as them. This was mitigated by sharing what the research is about and 



 44 

providing the respondents with the interview consent form timeously, before 

setting up the interviews. 

 

Administrative Limitations: 

• Accessing respondents – some respondents preferred face to face interviews, 

which brought logistical complexities as the country was under Covid-19 

lockdown most of the time. 

• Time Frames – the research was carried out under limited time frames and any 

slippage of time management had an impact on the final submission of the 

report. This was mitigated by being patient and ensuring that most of the 

identified personnel are interviewed, although the initial target submission date 

was not met, the researcher is grateful that the interviewee made time which 

ensured that the research objectives are achieved at the end.  

 

 



 45 

CHAPTER 4: PRESENTATION OF RESEARCH 
RESULTS 
 

4.1 Introduction 

 
The research results are presented in this section, answering the following three research 

questions as posed in section 1.2.3: 

1. What are the main challenges facing the SA junior coal mining sector, as well as 

their root causes? 

2. What are the key enablers of a sustainable junior coal mining sector? and 

3. What is the potential of the SA junior coal mining sector, and what does it take 

for this sector to reach its potential? 

 

4.2 The main challenges facing the SA junior coal 
mining sector 

The main challenges facing the South African junior coal mining sector, as well as their 

underlying root causes are presented. It is critical to understand the challenges and their 

underlying causes, to eliminate the root causes of identified challenges to build a strong 

and sustainable junior coal mining sector in SA. This was achieved through interviewing 

the leadership of SA junior coal producers as well as key stakeholders in the sector.  

 

Eight out of twelve junior coal mining companies (Companies A to H in Appendix 

3.1), representatives from the Minerals Council South Africa (MINCOSA), as well as the 

Department of Mineral Resources and Energy (DMRE) were interviewed and the 

summary of the interview results in terms of the key challenges facing the SA junior coal 

mining sector and their underlying root causes are summarised in Figure 4 and Table 1 

respectively. 

 



 46 

 

88%

63%

50%

25%

13% 13% 13% 13%

4%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Lack of Access
to Funding

Lack of Access
to Markets

Lack of Good
Quality

Resources

Lawlessness at
All Levels

Policy - Lack of
Execution Plan

Lack of Access
to DMRE

Lack of
Capacity

within DMRE

Lack of
Geological

Data

Lack of Skills

Main Challenges Facing the Sector According To Junior Mining Companies 

 

Figure 4: The key challenges facing the SA junior coal sector according to SA junior coal miners 

 

 
The junior coal mining companies interviewed as part of this study believe that the top 

four key challenges facing the SA junior coal mining sector in descending order are as 

follows: 

• Lack of access to funding – raised by 88% of the participants; 

• Lack of access to markets – highlighted by 63% of the participants;  

• Lack of Access to good quality coal resources – mentioned by 50% of the 

participants; and 

• Lawlessness at all levels – raised by 25% of the participants. 

 

The results in Figure 4 are the responses to the question, “what are the main challenges 

facing the South African junior coal mining sector”? 

 

The underlying root causes for the top three key challenges as highlighted by the SA 

junior coal miners are summarised in Table 1 below. 

 

 



 47 

Table 1: The underlying root causes of the top three key challenges facing the sector 

No Key Challenges Underlying Root Causes

1 Lack of access to Funding
The drying out of traditional funding instruments due to the current campaign to move away from 

fossil fuels to renewable energy resources (climate change)

Domestic Market  – lack of enforcement of preferential procurement policy to ensure Eskom as the 

largest domestic consumer of coal procures certain volume of their annual coal consumption from 

junior miners.

Export Market – lack of access to rail (Transnet Freight Rail) and port (Richards Bay Coal Terminal) 

where highlighted as major impediments to export markets.

2 Lack of access to Markets

3
Lack of access to good quality, long 

life coal resources

Good quality, long life coal resources have been taken by major coal producers as they have stronger 

balance sheets to explore for better quality coal resources.

 

 

Despite most of the interviewed companies highlighting the top three key challenges 

mentioned above, Company B, which is like the other junior coal miners, that is, it has 

prospecting rights, mining rights and operating mines, differed with the others when it 

comes to lack of access to funding. Company B believes that lack of access to funding is 

a symptom of another key challenge, which is “lack of execution plan” for the country’s 

mineral policy, and its owner and Chief Executive Officer (CEO) made comparisons to 

countries like Canada and Australia, highlighting that, the difference between SA and 

these countries is that, when a mineral policy is developed, it is accompanied by a clear 

execution plan to ensure that the mineral policy objectives are met. 

 

The other challenges highlighted by the junior coal miners include lawlessness at all 

levels, lack of execution plan to the existing mineral policy, lack of capacity within the 

DMRE, lack of geological data and lack of skills. The lawlessness was highlighted in 

relation to some of the uncontrollable community protests that often result in loss of 

mine property, as well as prolonged production interruptions. 

 
Table 2 shows the summary of key challenges facing the SA junior coal mining sector 
according to MINCOSA and the DMRE. 

 
Table 2: The key challenges facing the sector according to MINCOSA and the DMRE 

 
Description Key Challenges

1. Most junior miners, not just coal are under-resourced (e.g. most junior miners lack financial resources to attract and 

retain critical skills in-house).

2. They also lack capabilities that are needed to navigate the coal mining environment (those necessary capabilities are 

almost non-existent in junior miners).

The DMRE agrees with the junior miners on the top three challenges facing the sector, which are:

1. Lack of access to funding.

2. Lack of access to markets.

3. Lack of access to good quality resources.

MINCOSA

DMRE

 
 



 48 

The problem tree analysis of the challenges facing the SA junior coal mining sector 

under the literature review section of this study (section 2.2), indicates that lack of 

enabling mineral policy that enables investments in the sector is the root cause of the 

challenges facing this sector. So, as part of this research, further questions where posed 

to the participating junior coal  mining companies, to understand some of the mineral 

policy related challenges they encounter along the mining projects development value 

chain, with special focus on applications for prospecting rights, mining rights and  

running operational mines and the results are summarised in Table 3 to Table 5. 

 



 49 

Table 3: Practical experience by coal junior miners in applying for prospecting rights 

1. How Long did it take to obtain your Prospecting Right?
2. What was your experience with the process and your interaction with 

the DMRE?

3. Do you think there is any room for improvement in the application 

process?

The companies interviewed indicated that a prospecting right application can 

take anything between 6months to 7years before it is granted. The worst case 

was experienced by Company D, which applied in 2014 and was still awaiting 

for their application to be granted by December 2021. The time lines 

experienced by the different junior coal miners are summarised below: 

1. Company A - 18months;

2. Company B - less than a year  to 5years;

3. Company C - never dealt with prospecting rights applications;

4. Company D - 7years;

5. Company E - never dealt with prospecting rights applications;

6. Company F - never dealt with prospecting rights applications;

7. Company G - never dealt with prospecting rights applications; and

8. Company H - 12months.

Negative experience, especially with the manual application system (filling 

remains a