Choices: The proposed site of the Musina-Makhado Special Economic Zone in the Limpopo Valley is on Malumbwane land but residents are divided over the zone. (James Puttick)
Scaling back on the size of the Musina-Makhado Special Economic Zone (MMSEZ) and the negative effects it will have on the environment is not good enough, say opponents, who are calling for a new environmental impact assessment (EIA) for site clearance.
The initiative is to be the country’s largest planned special economic zone, with a metallurgical and energy cluster consisting of 20 industrial steel and ferrochrome components and fed by a 3 300 megawatt (MW) coal-fired power plant.
The proposed zone is near the Beitbridge border post and comprises two sites, Artonvilla near Musina and Bokmakierie, 50km south of Musina in the Limpopo Valley. It falls within the Unesco-proclaimed Vhembe Biosphere Reserve.
All these industries will rely on coal for energy and pose serious threats to local residents and the environment, say environmental organisations, scientists and lawyers.
Now, after fierce opposition to the project, the proponents of the controversial multibillion-rand mega-industrial project in the biodiversity-rich Limpopo Valley are considering revised proposals that will see its size cut from 8 000 hectares to 4 500ha and the coal-fired power plant reduced from 3 300MW to 1 320MW, among other changes.
‘Window-dressing’
But opponents argue that a mere reduction in the size of the zone and “some window-dressing exercises” are not sufficient for them to support the zone.
“It doesn’t change anything,” said David Tshidzumba, the youth leader of Save our Limpopo Valley Environment (Solve). “They still don’t want to take into account the cumulative impact that such a project is going to have on the environment.”
Johan Fourie, the deputy chairperson of environmental organisation Solve, is also sceptical. “The new proposal is nothing more than a window-dressing
exercise to coax locals and the anti-MMSEZ group into believing the investor is now environmentally friendly, wants to save the natural environment and is prepared to listen to the concerns of the people,” he said.
Fourie argues that the effect on the natural environment remains devastating and the coal-fired power station is the first project that should have been scrapped and replaced with renewable energy sources.
The heavy metallurgical industries will be responsible for most of the noise, air and water pollution and will destroy the sense of place of this part of the Limpopo Valley, he said.
Another critic, who did not want to be named, agreed. “The ‘foot in the door’ principle applies … If you grant this in whatever form, what guarantee is there that it is not going to be expanded further on the basis that it’s there?”
No such thing as ‘clean’ coal
Shavana Mushwana, a spokesperson for the zone, said the alternatives have been considered after “listening to and hearing the concerns of stakeholders”.
He said that more specialist studies will be conducted, following recommendations made during the public participation process.
The commitment, said Mushwana, is to upgrade the “clean” coal technology to “ultra-super” critical technology and, once operational, the MMSEZ will integrate renewable energy into the energy mix. This may include photovoltaic panels on roofs and solar farms, while an integrated waste disposal solution will “reduce the size of the waste management area over time”.
The coal power plant will be retained because there is “no alternative source of energy that can successfully meet the demands of the envisaged metallurgical cluster”, he said. The remaining energy will be fed into the electricity grid.
The development of new “clean coal” technologies allow for higher efficiencies and lower emissions and “reduces the overall impact on the environment”, said Mushwana.
But, Michelle Koyama, an attorney at the Centre for Environmental Rights, said there is no such thing as “clean coal”.
“Even with higher efficiency, there is no viable technology that can sufficiently and substantially mitigate all the harms of burning coal for electricity.
“Moreover, there will be 12 other industrial facilities, which will form part of the industrial zone and which would also use coal for their operations,” she said, adding the power plant will “eat” into the country’s carbon budget.
New assessment needed
Koyama said it appears as if there is a lot of new information that has not been made public and the project is “vastly different” from that initially proposed.
“It would be prudent and necessary for the project proponent to conduct a fresh EIA under these circumstances.”
She said the interested and affected parties had commented on numerous occasions during the EIA process for site clearance that specific information is lacking in the scientific reports and the EIA, “particularly the issues related to climate change, energy, water and socioeconomic impacts”.
There were also procedural irregularities, including inadequate public participation and the conflict of interests of the Limpopo department of economic development, environment and tourism (Ledet) and the implementing agent, the Limpopo Economic Development Agency (Leda).
“Despite these critical flaws, Ledet did not refuse the application, but instead sought to fill the gaps by conducting another round of public participation, and to request the environmental assessment practitioner at this stage to find an alternative site (which should have been done during the initial assessment), and to address the various gaps pertaining to energy and water.”
Residents of Tshikuwi village near the zone collect water from communal taps. There is a concern that water resources are not sufficient to supply the zone. (James Puttick)
Legal challenge
In recent weeks, environmental attorney Christo Reeders, whose clients include the Vhembe Biosphere Reserve and the Endangered Wildlife Trust, has sent hard-hitting letters to Ledet, arguing it is unlawfully trying to give the MMSEZ a further opportunity to supplement the final EIA report submitted in February because “it does not want to make a negative decision”.
He wrote that the 107-day peremptory period prescribed in the EIA regulations lapsed on 19 May and “there is therefore no alternative to you but to issue a negative decision” for environmental authorisation failing which high court review proceedings will be followed.
The EIA regulations provide neither further provision for addressing fatal flaws during the EIA process, nor for further extension to redress the flaws and shortcomings, following submission of the final EIA report. That the final EIA doesn’t pass muster, “is the most effective negative decision you can find”, Reeders told the Mail & Guardian.
The Ledet did not respond to questions from the M&G.
Mushwana said: “It is the MMSEZ’s understanding that the competent authority can only adjudicate on an application based on the submitted final EIA report by the applicant.
“MMSEZ is complying with the directives of the competent authority to conduct further public participation and provide a comprehensive mitigation plan before submitting the final EIA report in due course.”
Considerable effort
Lisa Thompson, of the African Centre for Citizenship and Democracy in the School of Government at the University of the Western Cape, said: “If the enabling agency, Leda, actually stuck to the mitigation effects that they built in here, and the advice in the specialist reports that they have requested, certainly I would have to say in all fairness that there has been a considerable effort to take into account the comments of IAPs [interested and affected parties], of environmental groups, and of everybody who has been involved in commenting.
“Except, one has to remember that many of the communities that are going to be affected by the
zone actually only registered as IAPs for this last round of public participation, which was disrupted,” adding the process is on pause while the legality of the extended timeframe is clarified.
Ecologically sensitive
The proposed southern site of the project has more than 100 000 trees, including baobabs, marula and mopane, and is described as “near pristine Bushveld wilderness” by the project’s environmental consultants.
Mushwana said the MMSEZ will “avoid as best as possible” development on ecologically sensitive areas such as wetlands and will “substantially reduce” the number of fauna and flora to be relocated, retaining most of the affected protected trees.But, said Fourie, “I cannot see how it makes any logical sense if the footprint of the development is reduced by half that all the protected flora will now suddenly be saved? Surely there must be protected trees within the 4 500 hectares which will have to be moved, transplanted and for which a [biodiversity] offset area will be needed?”
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