FORMAL REQUEST TO SUBMIT COMMENTS ON THE FINAL SCOPING ASSESSMENT REPORT OF THE PROPOSED MUSINA- MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE

The Centre for Environmental Rights (CER), representing groundWork and Earthlife Africa, has formally requested the opportunity to comment on the final scoping assessment report for the proposed Musina-Makhado Special Economic Zone (SEZ). The CER objects to the adequacy of the public participation process and the content of the scoping report, requesting that the environmental impact assessment (EIA) process be paused until detailed objections are submitted.

• The Centre for Environmental Rights (CER) and its clients, groundWork and Earthlife Africa, object to the public participation process for the Musina-Makhado Special Economic Zone's environmental impact assessment (EIA), stating it was "inadequate". The CER notes that despite requesting registration as interested and affected parties (I&APs) on 7 December 2018, confirmation was only received from Delta Built Environmental Consultants on 8 July 2019, and they were not notified of the scoping report's approval on 19 August 2019.
• The CER identifies several areas where the scoping report is "wholly inadequate", including the consideration of alternative options, the viability and need for the development, and water supply and use. Specifically, the CER highlights "insufficient consideration of climate change impacts", citing the proposal for a "3 300 MW thermal power plant which will rely primarily on coal".
• The CER argues that the current EIA process under the National Environmental Management Act: Impact Assessment Regulations is "inappropriate" due to uncertainties regarding industrial scale, service provisions, and infrastructure needs. They propose that a "strategic environmental assessment" be conducted instead to provide a sustainability framework and integrate environmental sustainability into the SEZ planning.
• The CER has requested that the EIA process be held in abeyance and the scoping phase be re-conducted with proper consultation. They proposed a deadline of 1 October 2019 to submit detailed comments on the final scoping report to avoid seeking "alternative means of relief".

APA

Centre for Environmental Rights (2019). FORMAL REQUEST TO SUBMIT COMMENTS ON THE FINAL SCOPING ASSESSMENT REPORT OF THE PROPOSED MUSINA- MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE. https://cer.org.za/wp-content/uploads/2019/11/Annexure-A-CER-letter-of-4-9-19-1.pdf?x21779

Chicago

Centre for Environmental Rights. FORMAL REQUEST TO SUBMIT COMMENTS ON THE FINAL SCOPING ASSESSMENT REPORT OF THE PROPOSED MUSINA- MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE. 2019. https://cer.org.za/wp-content/uploads/2019/11/Annexure-A-CER-letter-of-4-9-19-1.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=FORMAL REQUEST TO SUBMIT COMMENTS ON THE FINAL SCOPING ASSESSMENT REPORT OF THE PROPOSED MUSINA- MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE |date=4 September 2019 |url=https://cer.org.za/wp-content/uploads/2019/11/Annexure-A-CER-letter-of-4-9-19-1.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2019formal, author = {{Centre for Environmental Rights}}, title = {{FORMAL REQUEST TO SUBMIT COMMENTS ON THE FINAL SCOPING ASSESSMENT REPORT OF THE PROPOSED MUSINA- MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE}}, publisher = {Centre for Environmental Rights}, year = {2019}, month = sep, url = {https://cer.org.za/wp-content/uploads/2019/11/Annexure-A-CER-letter-of-4-9-19-1.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }