OBJECTIONS TO THE DRAFT ENVIRONMETAL IMPACT 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, Earthlife Africa (ELA), and MEJCON-SA, submitted formal objections on 22 October 2020 to the Draft Environmental Impact Assessment Report (DEIR) for the proposed Musina-Makhado Special Economic Zone (MMSEZ), also known as the Energy Metallurgical Special Economic Zone (EMSEZ). The CER argues that the project's negative environmental and social impacts far outweigh its potential benefits and that the environmental authorisation (EA) should be refused due to severe flaws in the assessment process, conflict of interest in the decision-making authority, and significant threats to climate, water, and health.

• The proposed project involves clearing 8,000 hectares of near-pristine bushveld for heavy industries, including a 3,300MW coal-fired power station, coal washery, and various metallurgical plants (ferrochrome, ferromanganese, silicomanganese, vanadium, steel, lime, and cement).
• The project is predicted to have a high negative impact on climate change, with estimated total greenhouse gas (GHG) emissions accounting for 11% to 16% of South Africa's total carbon budget.
• The project would cause the direct and permanent loss of approximately 4,754 hectares of natural habitat, including Mopane Bushveld, Riparian Habitat, and Ridge Bushveld, threatening critically endangered species such as Marula and Mopane trees.
• The CER alleges a blatant conflict of interest because the applicant, Limpopo Economic Development Agency (LEDA), is 100% owned and financed by the decision-making authority, the Limpopo Department of Economic Development, Environment and Tourism (LEDET).
• The CER argues that the Minister of Environment, Forestry and Fisheries is the correct competent authority rather than LEDET, as the project's impacts on water and air pollution traverse international boundaries into Zimbabwe, Botswana, and Mozambique.
• The DEIR is criticized for missing critical data, including a detailed Social Impact Assessment, separate geohydrological and groundwater assessments, and an Avifaunal Impact Assessment.
• The Air Quality Impact Assessment (AQIA) is described as fatally flawed due to the use of an arbitrary and too-small modelling domain (50km), the omission of fugitive dust emissions, and the use of distant baseline data from Mokopane and Phalaborwa.
• The Health Impact Assessment (HIA) is deemed grossly incomplete because it lacks quantitative health risk assessments and fails to provide evidence for its conclusions that mitigation would reduce health impact significance from 'high' to 'moderate'.
• The project threatens several protected areas and heritage sites, including the UNESCO Vhembe Biosphere Reserve, Mapungubwe Cultural Landscape (a UNESCO World Heritage Site), and the Makuleke Wetlands (a RAMSAR site).

APA

Centre for Environmental Rights (2020). OBJECTIONS TO THE DRAFT ENVIRONMETAL IMPACT 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/2020/11/gW-ELA-and-MEJCON-Objection-to-the-EMSEZ-DEIR-22.10.2020.pdf?x21779

Chicago

Centre for Environmental Rights. OBJECTIONS TO THE DRAFT ENVIRONMETAL IMPACT ASSESSMENT REPORT OF THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE. 2020. https://cer.org.za/wp-content/uploads/2020/11/gW-ELA-and-MEJCON-Objection-to-the-EMSEZ-DEIR-22.10.2020.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=OBJECTIONS TO THE DRAFT ENVIRONMETAL IMPACT ASSESSMENT REPORT OF THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE |date=22 October 2020 |url=https://cer.org.za/wp-content/uploads/2020/11/gW-ELA-and-MEJCON-Objection-to-the-EMSEZ-DEIR-22.10.2020.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2020objections, author = {{Centre for Environmental Rights}}, title = {{OBJECTIONS TO THE DRAFT ENVIRONMETAL IMPACT 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 = {2020}, month = oct, url = {https://cer.org.za/wp-content/uploads/2020/11/gW-ELA-and-MEJCON-Objection-to-the-EMSEZ-DEIR-22.10.2020.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }