OBJECTIONS TO THE DRAFT ENVIRONMETAL IMPACT ASSESSMENT REPORT OF THE PROPOSED MUSINAMAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE

The Centre for Environmental Rights, representing groundWork, Earthlife Africa, and MEJCON-SA, objects to the Musina-Makhado Special Economic Zone (MMSEZ) based on severe climate, water, and health risks. The document argues that the project's estimated greenhouse gas emissions would account for 11%-16% of South Africa's total carbon budget and that the region lacks sufficient water to support the development. It further alleges a conflict of interest, as the decision-making authority (LEDET) is the holding company of the project applicant (LEDA). The objectors claim the DEIR is fatally flawed due to missing social and geohydrological impact assessments and an inadequate public participation process.

• The proposed project is predicted to have a significant impact on climate change, with estimated total greenhouse gas (GHG) emissions between 11% and 16% of South Africa's total carbon budget.
• There is a critical deficit of water required for the project's development and operation, with a projected deficit of 168 million m³ during the final operational phase.
• 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 like Marula and Mopane trees.
• A blatant conflict of interest exists because the decision-maker, the Limpopo Department of Economic Development, Environment and Tourism (LEDET), is the holding company of the applicant, the Limpopo Economic Development Agency (LEDA), holding 100% equity.
• The project's development footprint traverses international boundaries, as it would create pressure on water resources in Zimbabwe and impact air quality in Botswana, Zimbabwe, and Mozambique, meaning the national Minister should be the competent authority under NEMA.
• The DEIR is missing critical specialist reports, including a detailed Social Impact Assessment, separate geohydrological and groundwater assessments, and an Avifaunal Impact Assessment.
• The Air Quality Impact Assessment (AQIA) is flawed because it uses baseline data from stations over 180 km away (Mokopane and Phalaborwa) and fails to model fugitive dust emissions from all sources.
• The project threatens several protected and heritage sites, including the UNESCO Vhembe Biosphere Reserve, Mapungubwe Cultural landscape, and the Makuleke Wetlands.
• The project is expected to negatively impact the regional agricultural economy, with potential annual revenue losses of R765.59 million if tomato farming is affected by water shortages.
• The public participation process was inadequate, relying on only two newspaper advertisements and providing technical reports in a zipped English-only format that is inaccessible to many local communities.

APA

Centre for Environmental Rights (2020). OBJECTIONS TO THE DRAFT ENVIRONMETAL IMPACT ASSESSMENT REPORT OF THE PROPOSED MUSINAMAKHADO 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 MUSINAMAKHADO 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 MUSINAMAKHADO 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 MUSINAMAKHADO 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} }