This is written in response to the opinion piece by the chief executive of the Musina-Makhado Special Economic Zone (MMSEZ), Lehlogonolo Masoga, published by the Mail & Guardian on 12 May 2021.
I am a registered interested and affected party (I&AP) in the MMSEZ’s environmental impact assessment (EIA) process. I am an attorney and have been working extensively on the EIA, as well as with local residents in supporting them to understand the risks that come with the MMSEZ. I find myself disturbed by the glowing and, in places, false picture painted by Masoga in his opinion piece.
The headline, “The Musina-Makhado zone puts people first, says its chief executive”, is to be questioned. If people were put first, the MMSEZ state-owned corporation, along with the Limpopo Economic Development Agency (Leda), would have ensured more inclusive and thorough EIA and public participation processes. Instead, prescribed timelines have not been adhered to, and scant effort appears to have been made to ensure that a broad range of stakeholders is meaningfully informed about the potential environmental impacts.
Until stakeholders exerted pressure, public participation meetings were not being translated into local languages. Meetings generally entailed a 45-minute PowerPoint presentation filled with text-dense descriptions covering only certain aspects of the project. Question and answer sessions had time limits, specialists were not present to answer questions and issues could only be superficially discussed. The EIA process appears to have been suspended and, according to sources, is under imminent threat of being taken on legal review because of alleged noncompliance with certain prescripts of the National Environment Management Act.
One of the much-vaunted benefits to people is supposed to be the 53 800 jobs that have been referred to by the project’s proponents. Either Leda or the MMSEZ have been repeatedly asked at public participation meetings and in our objections to provide details of what jobs would be available, what the skills profiles of such jobs are, whether these will be construction, or operation and whether these are local or outsourced. This information is yet to be forthcoming, and the economic assessment does not deal adequately with this
Masoga’s article opens with reference to, and implied alignment with, sustainable development and global climate change efforts. This is ironic given that the expected greenhouse gas emissions from the MMSEZ emit one billion tonnes of carbon dioxide equivalent of direct and energy indirect emissions over the lifetime of the project. Using the 2020 industry benchmark emissions intensities, this means the emissions will take up 14% of South Africa’s carbon budget if the country adheres to a reduction trajectory that supports the Paris Agreement’s 2°C temperature increase target. This jumps to 24% of the carbon budget if a 1.5°C temperature increase is targeted, as is urged by scientists.
The comparison to the Tesla Gigafactory is also problematic. That facility was constructed on zoned industrial land. It is situated in a region that is industrialised and has the infrastructure to support heavy industrial activities. The site near Berlin contained low value monocrops prior to construction, in strong contrast to the biodiversity rich area in which the zone is proposed. The relocation of a handful of species pales into insignificance compared with relocating more than 100 000 mature protected trees such as protected baobabs, marula and mopane trees.
It is also misleading to imply alignment with carbon reduction and exiting from coal power, when the SEZ project, as assessed, includes a 3 300 megawatt (MW) coal-fired power station and many carbon intensive heavy metal industries. Even if the power station is reduced to 1 320MW, as was informally proposed, this is still significant and the other high emissions metallurgical plants remain.
The MMSEZ introduces high impacts from water use, atmospheric emissions, greenhouse gas emissions, biodiversity loss and cultural and heritage loss, not only at the site but in the broader region. Making a comparison to a different type of development in another country has little value.
The article speaks of the “art of mitigation”. Impact mitigation is indeed a route to finding a balance. Unfortunately, in the zone’s EIA process, mitigation is often treated in a superficial and unquantified manner in many of the specialist reports. One essential mitigation measure that was stipulated by the climate impact assessment practitioners is that the coal-fired power station should not go ahead without carbon capture and storage being installed from the beginning. Carbon capture and storage does not viably and practicably exist at any meaningful scale and it has been soundly rejected by the operator, SAEMB (Pty) Ltd, according to their correspondence.
Mr Masoga claims that “One of the defining features of the public participation process experiences was the constructive and strategic relationships the Limpopo Economic Development Agency (Leda) built with a consortium of civil society and environmentalist organisations represented through the Centre for Environmental Rights (CER).”
The CER disputes these contentions. In its letter to the Mail & Guardian editor the CER says, “These statements about CER are not correct. Any representation that a ‘constructive and strategic relationship’ has been built between Leda and other civil society and environmental organisations represented by CER, or between Leda and CER, is false.”
Earthlife Africa’s Makoma Lekalakala says; “We have interacted at the public participation meetings, but the only interaction we have had with Mr Masoga was when he introduced himself after the public meeting in Musina on the 28th of April. We requested him to formalise an invitation to meet with him after he said he would like to discuss the project, but this has not happened so far.“
A project of this magnitude requires accurate, complete assessment and meaningful public participation, so that a solid evaluation can be made about whether people are indeed being put first.
Brandon Abdinor is a registered I&AP for the MMSEZ EIA process.