OBJECTIONS TO THE SEPTEMBER 2021 “FINAL” ENVIRONMENTAL IMPACT ASSESSMENT REPORT [REVISION 03] OF THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE (LIM/EIA/0000793/2019)

The Centre for Environmental Rights (CER), representing groundWork, Earthlife Africa, and the Mining and Environmental Justice Community Network of South Africa, submitted formal objections to the September 2021 Final Environmental Impact Assessment Report (FEIR) for the proposed Musina-Makhado Special Economic Zone (MMSEZ). The CER argues that the EIA process is unlawful, procedurally irregular, and based on inadequate specialist assessments, concluding that the project's negative impacts on climate, water, and health outweigh its projected benefits.

• The CER contends that the EIA process is unlawful because it continued beyond the legal deadline of 19 May 2021. According to the document, the decision-maker was required to grant or refuse the application within 107 days of the February 1, 2021 submission, and no lawful extension was granted.
• There is a significant conflict of interest between the applicant and the decision-maker. The Limpopo Economic Development Agency (LEDA), the applicant, is wholly owned and financed by the Limpopo Department of Economic Development, Environment and Tourism (LEDET), which is the decision-maker for the project.
• The CER argues that LEDET lacks the legal authority to be the competent authority for the project. Under the National Environmental Management Act (NEMA), the national Minister of Forestry, Fisheries and Environment should be the authority because the project traverses international boundaries, impacts national conservation sites, and is undertaken by a provincial department.
• The public participation process was allegedly flawed due to inadequate notification of interested and affected parties (I&APs), password-protected documents, and the failure to provide a full 30-day comment period for all technical reports.
• The FEIR is accused of using inflated and misleading employment figures to create unrealistic expectations. While the report mentions 53,800 jobs, the CER claims that during community meetings, a figure of 800,000 jobs was presented, which refers to indirect employment and is not supported by the report's own data.
• The project's climate change impacts are described as 'VERY HIGH' and irreversible. The project is expected to generate approximately 1 billion tonnes of carbon dioxide equivalent over its lifetime, potentially contributing between 10% and 24% of South Africa's carbon budget depending on the global warming target (1.5°C or 2°C).
• There is a critical lack of guaranteed water supply for the MMSEZ. The project's estimated demand of 80 million m3/annum is viewed as unsustainable, with the FEIR admitting that water is only available for the first year and that feasibility studies for bulk water supply from Zimbabwe are still pending.
• The CER claims the FEIR fails to adequately assess cumulative impacts by separating land clearance from the operational impacts of proposed industries, such as coal-fired power stations and heavy metal plants.
• The FEIR is criticized for failing to identify and protect sacred sites and traditional knowledge. While the report identifies 19 sacred burial sites, community members claim there are over 200, and the report ignores the spiritual significance of forests, rivers, and baobab trees.
• The proposed biodiversity offset is deemed impractical. The CER states that available offset areas are too small to meet requirements and that the loss of critical biodiversity areas, soils, and cultural heritage is 'definite'.

APA

Centre for Environmental Rights (2021). OBJECTIONS TO THE SEPTEMBER 2021 “FINAL” ENVIRONMENTAL IMPACT ASSESSMENT REPORT [REVISION 03] OF THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE (LIM/EIA/0000793/2019). https://cer.org.za/wp-content/uploads/2022/03/ELA-gW-MEJCON-objections-to-MMSEZ-Enviroxcellence-FEIR-3.11.2021.pdf?x21779

Chicago

Centre for Environmental Rights. OBJECTIONS TO THE SEPTEMBER 2021 “FINAL” ENVIRONMENTAL IMPACT ASSESSMENT REPORT [REVISION 03] OF THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE (LIM/EIA/0000793/2019). 2021. https://cer.org.za/wp-content/uploads/2022/03/ELA-gW-MEJCON-objections-to-MMSEZ-Enviroxcellence-FEIR-3.11.2021.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=OBJECTIONS TO THE SEPTEMBER 2021 “FINAL” ENVIRONMENTAL IMPACT ASSESSMENT REPORT [REVISION 03] OF THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE (LIM/EIA/0000793/2019) |date=3 November 2021 |url=https://cer.org.za/wp-content/uploads/2022/03/ELA-gW-MEJCON-objections-to-MMSEZ-Enviroxcellence-FEIR-3.11.2021.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2021objections, author = {{Centre for Environmental Rights}}, title = {{OBJECTIONS TO THE SEPTEMBER 2021 “FINAL” ENVIRONMENTAL IMPACT ASSESSMENT REPORT [REVISION 03] OF THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE (LIM/EIA/0000793/2019)}}, publisher = {Centre for Environmental Rights}, year = {2021}, month = nov, url = {https://cer.org.za/wp-content/uploads/2022/03/ELA-gW-MEJCON-objections-to-MMSEZ-Enviroxcellence-FEIR-3.11.2021.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }