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.
More than 20 organisations and individuals have sent an open letter to the minister of environment, forestry and fisheries, Barbara Creecy and the minister of trade, industry and competition, Ebrahim Patel calling for national-level oversight in the the controversial planned Chinese-backed Musina-Makhado Special Economic Zone (MMSEZ) metallurgical and energy cluster.
The letter, initiated by Earthlife Africa, calls for an integrated assessment of the “overall value proposition” of the project’s coal-based, mega-project approach to development, which is being championed by the Limpopo provincial government.
The metallurgical and energy cluster, South Africa’s largest single planned SEZ, will consist of 20 industrial steel and ferrochrome components, fed by a 3 300MW coal-fired power plant.
“All these industries are highly reliant on coal for energy and pose serious threats to local communities and the environment,” said Earthlife Africa director Makoma Lekalakala at a media briefing on 17 March to launch the open letter.
Limpopo, she said, is severely water-stressed and is a climate change and biodiversity hotspot.
In the open letter the signatories state any new minerals development, beneficiation projects or infrastructure investment should not be premised on expanding coal value chains, either nationally or internationally, nor increase South Africa’s dependence on or combustion of coal.
“Rather it should be aligned with long-term sustainability and a just transition to a zero-carbon economy,” it reads.
Signatories include the Centre for Environmental Rights, the Centre for Applied Legal Studies (Cals), 350Africa.org, Save our Limpopo Valley Environment, WWF-SA, BirdLife South Africa, African Centre for Citizenship and Democracy (Accede), Greenpeace Africa, groundWork, the Alternative Information and Development Centre and Project 90 by 2030.
The letter has addressed both ministers “as it is not clear how big-picture issues are to be addressed” or the extent to which SEZ legislation may be supportive of an integrated assessment of the overall value proposition, which is “essential and not addressed under the incremental approach being taken” to environmental impact assessment (EIA).
The signatories are concerned about potential conflicts of interest because the Limpopo department of economic development, environment and tourism is responsible for an objective assessment of the proposition’s socioeconomic merits, under the EIA, while the Limpopo Economic Development Agency is championing the MMSEZ.
It is clear that prospective water supply options to supply the SEZ that are being considered by Limpopo have not been meaningfully assessed and remain highly speculative, the letter reads. It asks for information on engagement or communication by the national government with the regional body that has oversight of the Limpopo River catchment area – the Limpopo Basin Commission – and/or with the Limpopo North Catchment Management Agency.
The final EIA for the first phase of development — site clearance — was released last month by Delta Built Environmental Consultants for the Limpopo Economic Development Agency. On 4 March, the Limpopo economic development department referred the EIA back to Delta, describing the process as insufficient or incomplete.
“The public participation process was conducted in English, and not in any of the local languages (Sepedi, Xitsonga and Tshivenda), thus denying the interested and affected parties to meaningfully participate … Sources of water and energy supply have not been explicitly outlined,” the department stated.
A flawed process
The media briefing heard how the public participation process was flawed as it occurred during level three lockdown, with meetings allowing no more than 50 people to gather, and these being called at short notice.
Accede director Lisa Thompson said it was ironic that the EIA had been referred back to Delta. “The EIA document is 996 pages. The environmental assessment practitioner did request the department for an extension because of the fact the public participation process happened in stage three lockdown.
The department “did not extend the deadline but now is referring it back … because I’m fairly sure they’re worried about litigation around a flawed public participation process,” she said.
Further public participation “opens a unique opportunity to inform communities” about the project, she said, adding the EIA is an incredibly “confused” document.
“On the one hand it says the environmental effects are going to be very dire and then on the other it says the project is part of a sustainable development initiative, which is hard to believe.”
The MMSEZ, she said, is linked to China’s Belt and Road Initiative. “It’s part of a developmental drive rewiring trade and investment in ways that direct these flows more towards what is known as the global south. In that sense it’s an incredibly important project. And I think for that reason many of the dirty energy aspects of the zone have been underplayed.”
Earthlife Africa associate Brandon Abdinor said the SEZ will be constructed and operated in an area the environmental specialists have described as near-pristine and water-scarce. “We’re talking about the entire character of this region being fundamentally altered,” he said, adding that a strategic approach is needed to look at the larger area under threat.
Dr Louis Snyman, the head of the environmental justice programme at Cals, said a “domino effect” is underway in northern Limpopo with a multitude of new mining licences and mining rights being granted in a short space of time to supply the SEZ.
“I think this is a coordinated effort among many departments, including the department of mineral resources and energy and the department of trade, industry and competition, who have identified the northern Limpopo region and the Tuli block and belt as a special interest zone.”
Northern Limpopo faces its greatest risk, Snyman said. “What we are going to be seeing in the next five to 10 years is the complete decimation of all sensitive biological fauna and flora in this particular area, which is already incredibly water-stressed.”