ENVIRONMENTAL IMPACT ASSESSMENT FOR THE PROPOSED METALLURGICAL CLUSTER OF THE MUSINA-MAKHADO SPECIAL ECONOMIC ZONE

The Centre for Environmental Rights (CER), representing Earthlife Africa, groundWork, and the Mining and Environmental Justice Community Network of South Africa (MEJCON-SA), submitted a formal objection to the Department of Economic Development Environment and Tourism in Limpopo regarding the Environmental Impact Assessment (EIA) for the Musina-Makhado Special Economic Zone (MMSEZ) metallurgical cluster. The CER argues that the Final Environmental Impact Report (FEIR) contains fatal flaws, including insufficient public participation and missing critical data on water and energy, and asserts that the application should have been refused by the regulatory deadline of 19 May 2021.

• The Department of Economic Development Environment and Tourism identified five critical gaps in the Final Environmental Impact Report (FEIR) for the MMSEZ Project in a letter dated 4 March 2021. These gaps include a lack of viable alternative sites, insufficient details regarding energy supply and water sources, the absence of a recommendation from the Environmental Assessment Practitioner (EAP), a lack of a public participation summary, and inadequate public participation due to meetings not being conducted in local languages.
• The Centre for Environmental Rights (CER) contends that the identified gaps constitute a "fatal flaw" to the EIA process. They argue that the failure to conduct adequate public participation and provide material information violates the National Environmental Management Act, 1998 (NEMA) and the Promotion of Administrative Justice Act, 2000.
• The CER objects to attempts to remedy the flawed EIA through further consultations without conducting new impact assessments. They note that during consultations on 28 and 29 April 2021 in Musina and Makhado, changes were mentioned—including a reduced project footprint and an additional buffer zone—which the CER argues effectively create a new project requiring a fresh EIA and expert reports.
• The CER asserts that the application for the MMSEZ Project should be refused because the 107-day deadline for a decision—calculated from the FEIR submission on 1 February 2021—expired on 19 May 2021 without the identified gaps being addressed.

APA

Centre for Environmental Rights (2021). ENVIRONMENTAL IMPACT ASSESSMENT FOR THE PROPOSED METALLURGICAL CLUSTER OF THE MUSINA-MAKHADO SPECIAL ECONOMIC ZONE. https://cer.org.za/wp-content/uploads/2021/05/CER-Letter-to-LEDET-re-EMSEZ-27.05.2021.pdf?x21779

Chicago

Centre for Environmental Rights. ENVIRONMENTAL IMPACT ASSESSMENT FOR THE PROPOSED METALLURGICAL CLUSTER OF THE MUSINA-MAKHADO SPECIAL ECONOMIC ZONE. 2021. https://cer.org.za/wp-content/uploads/2021/05/CER-Letter-to-LEDET-re-EMSEZ-27.05.2021.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=ENVIRONMENTAL IMPACT ASSESSMENT FOR THE PROPOSED METALLURGICAL CLUSTER OF THE MUSINA-MAKHADO SPECIAL ECONOMIC ZONE |date=27 May 2021 |url=https://cer.org.za/wp-content/uploads/2021/05/CER-Letter-to-LEDET-re-EMSEZ-27.05.2021.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2021environmental, author = {{Centre for Environmental Rights}}, title = {{ENVIRONMENTAL IMPACT ASSESSMENT FOR THE PROPOSED METALLURGICAL CLUSTER OF THE MUSINA-MAKHADO SPECIAL ECONOMIC ZONE}}, publisher = {Centre for Environmental Rights}, year = {2021}, month = may, url = {https://cer.org.za/wp-content/uploads/2021/05/CER-Letter-to-LEDET-re-EMSEZ-27.05.2021.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }