/ 22 October 2020

Muddying the waters in the Musina Makhado economic zone

No control: Lack of oversight at Sars has made life easier for cigarette smugglers such as this man crossing into Musina from Zimbabwe.
The Environmental Impact Assessment (EIA) of the Musina Makhado Special Economic Zone (SEZ) is touted by the government to be the new “regional economic epicentre” much like other mega-projects in the Global South.


The Environmental Impact Assessment (EIA) of the Musina Makhado Special Economic Zone (SEZ) is touted by the government to be the new “regional economic epicentre” much like other mega-projects in the Global South. 

Many of these projects drain the fiscus with heavy infrastructural requirements, heighten foreign extraction of resources and raise carbon pollution levels. Multinational companies, endorsed by governments for the fiscal kickbacks, commit to alleviate people’s poverty where the primary goal is to shift their need for Africa’s rich mineral resources and to offset their national carbon footprint. 

The Musina Makhado SEZ, or MMSEZ as it is now called by the government, is a perfect case in point. The zone will be the first in South Africa to be operated by a foreign (Chinese) company, Shenzhen Hoi Mor. The company has committed to investing $3.8-billion to its operational success. This will mean an unprecedented level of foreign control. To make matters worse, of the proposed industries in the metallurgical cluster, nearly all of them are carbon intensive, environmentally destructive and a threat to the livelihoods of communities in the medium term, as even the EIA admits they are environmentally red-flag carbon dioxide emitters.

The proposed list of industries includes a coal washery, a coking plant, a thermal plant, a ferrochrome plant, a ferromanganese plant, stainless steel, high manganese steel and high vanadium steel plants as well as lime and cement plants. The total pollution effect on the ecologically sensitive Vhembe district is devastating, with knock-on effects for the entire province and even neighbouring Zimbabwe.

The high-level EIA, as it is called, was completed by Delta Built Environment Consultants (Delta BEC) and made public on 1 September 2020. While admitting the environmentally harmful nature of the SEZ, the document is self-justificatory. 

The EIA assessment glosses over the endemic water scarcity issues in the Limpopo Valley stating: “… (i)f insufficient water is available in the catchment, and the social and economic opportunities offered by the SEZ operation are sufficiently attractive, additional water may be brought in from a neighbouring catchment”.

Although not unexpected, but still shocking, is the lack of community inclusion in the public participation process which, conveniently, was orchestrated during lockdown. All large-scale developmental initiatives, especially those with huge effects on communities, should abide by the principle endorsed by the United Nations Human Rights Council to expressly safeguard the rights of indigenous people, by “free, prior and informed consent” so that those affected participate from an informed base.

It is blatantly obvious that newspaper announcements are not enough to advertise a public participation process in remote areas such as Limpopo province. This is expressly articulated in the public participation guidelines published by the department of environmental affairs (1998) where it states “…ultimately, mechanisms may be used for engagement or even notification purposes must suitably allow for engagement of all I&APs [interested and affected parties] who may be illiterate or disabled or who may have any other disadvantage”.

EIAs the world over commonly overlook this commitment and the one in question is no exception. Although five meetings were held in total, public participation was minimal. The events were advertised in only two newspapers, one of which is not widely read in the Musina-Makhado area. Also, lockdown restrictions at the time allowed only 50 people to attend meetings.

Most don’t know about the zone

In October 2019 and in September 2020, straight after the public participation process, the African Centre for Citizenship and Democracy researchers undertook rapid appraisal vox pop surveys in Louis Trichardt, Musina and local settlements and also held focus group meetings with those living near the MMSEZ confirming that most of the local populations across gender, ethnic and class lines, were not aware of the public participation process, nor even knew of the proposed zone plan. Most do not know what an SEZ is.

The Mudimele community focus group meetings in September revealed their almost total lack of knowledge of the public participation process, even though they are closest to the zone and adjacent Coal of Africa  — now renamed MC Mining’s  — new expanded coal mine. The Vhembe mine is back on track, temporarily stopped by a 2019 court order, financially assisted by a recently renewed loan from the Industrial Development Corporation. Other mining deals are on the cards, mostly with Chinese companies gearing up to supply high-tech labour.

Because of the  poor public announcement of the EIA, a fact admitted to by Delta BEC at the Louis Trichardt meeting, the public participation meeting in Louis Trichardt was attended by exactly 15 people, even though the town is the closest to the proposed 8 000ha SEZ. 

Of the four other meetings held, one was “virtual” (held in Pretoria via webinar, so restricted to academics and business) and the other three were poorly attended. The one held in Mulambwane (near Musina) was attended by a youth contingent that was bussed in, complete with placards, supporting the SEZ on the basis of job creation. The Limpopo Economic Development Agency (LEDA) official at the meeting said in answer to a question about jobs for locals “possibly by Christmas”.

At the Louis Trichardt meeting, Delta BEC presenter Ronaldo Retief admitted that most of the 37 000 jobs the zone is purported to generate will be temporary, semi-skilled positions.

In an effort to combat the criticism about the public participation process, Delta BEC hastily organised another five meetings last week. Again, many communities did not know of the meetings held at short notice. While on paper the process now looks more robust, in reality most people are still poorly informed. 

EIA guidelines place this onus on the government, but in the case of the MMSEZ informing the public has fallen to environmental NGOs, such as Earthlife and Save our Limpopo Valley (Solve).

Another governmental method of watering down public objection is to obtain initial consent to something less developmentally controversial. In this case, the current high-level EIA is a predominantly site-clearing process of getting approval from the department of economic development; environment and tourism (LEDET). The carbon-intensive aspects of the proposed projects within the zone would all require separate environmental assessments. Each project will also have to apply for a water-use licence.

Although the EIA draws attention to the fact that the province is water scarce, the plans to alleviate water scarcity are ludicrously inadequate. The EIA states the plan to use what LEDA calls “surplus water capacity”, but water scarcity is endemic to the region, and a burgeoning of coal mining in the area, together with commercial farming, will not help to allay the situation.

Stupid science

Other implausible schemes mentioned in the EIA involve obtaining water from Zimbabwe, and building a dam on the Sand River, a perennial water source with variable, erratic  delivery capacity. Given that the zone will use in excess of 80 million cubic litres of water per year, this pie-in-the-sky thinking is simply stupid science.

The zone will undoubtedly cause a radical decrease in carbon sequestration in and around the zone. The EIA proposes to uproot and transplant some 100 000 mature trees growing in arid terrain. This plan is absurd even to the layperson, but from an environmental science point of view it is ridiculous. The flora and fauna of the area will be destroyed and the ecological balance of the Limpopo Valley changed forever.

So, while government officials punt the high-tech regional economic epicentre in Limpopo, the reality is that the post-covid development landscape in South Africa is about to get even dirtier, more extractivist and exploitative of the very poor communities that have the most to lose in terms of livelihood precarity, despite South Africa’s Just Transition commitments.

The EIA window for public comment for the MMSEZ ends at midnight tonight. NGOs and members of the public can still register objections via email:  [email protected] 

The views expressed are those of the author and do not necessarily reflect the official policy or position of the Mail & Guardian.