OBJECTIONS TO THE 7 DECEMBER 2020 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT [REVISION 01] 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, and the Mining and Environmental Justice Community Network of South Africa, submitted formal objections to the Revised Draft Environmental Impact Assessment (EIA) for the proposed Musina-Makhado Special Economic Zone (EMSEZ). The CER argues that the EIA is fatally flawed due to procedural unfairness, inadequate public participation, and significant gaps in specialist studies regarding climate change, water scarcity, air quality, and human health. The document asserts that the project's high negative environmental impacts likely outweigh its projected socio-economic benefits and that an environmental authorisation should be denied.

• The CER identifies a significant conflict of interest and lack of authority regarding the decision-maker. The Limpopo Department of Economic Development, Environment and Tourism (LEDET) is acting as the decision-maker despite being the holding company and financier of the applicant, the Limpopo Economic Development Agency (LEDA). The CER contends that the Minister of the Department of Environment Forestry and Fisheries (DEFF) is the correct competent authority because the project traverses international boundaries by drawing water from the Limpopo river and pipelines in Zimbabwe.
• The public participation process is described as ineffective and procedurally unfair. The CER notes a lack of notices in languages other than English and Venda, insufficient time for the public to comment, and the failure of specialists to incorporate previous public comments into the Revised Assessment due to time constraints imposed by LEDET.
• The EIA is criticized for using a 'segmented' approach that fails to assess the project holistically. By focusing primarily on land clearing and service infrastructure, the assessment relies on assumptions and lacks data on individual investor plants, fugitive emissions from various facilities, and closure-related impacts.
• The project is expected to have a 'VERY HIGH' impact on climate change, potentially generating 1 billion tonnes of carbon dioxide equivalent over its lifetime. This would represent between 10-14% of South Africa's carbon budget under a 2°C global reduction target and up to 23-24% under a 1.5°C target. The CER highlights that the proposed coal-fired power plant contradicts national emission reduction goals and risks becoming a stranded asset.
• Water supply for the EMSEZ is deemed insecure and potentially unlawful. The project requires 80 Mm3/a, but the CER argues that available sources—including the proposed Musina Dam—rely on floodwaters already allocated to other users. Furthermore, the assessment lacks a geohydrological study of groundwater and fails to account for the impact of withdrawing 4.4 Mm3/a from the Limpopo Aquifer.
• The air quality analysis is described as fatally flawed, relying on a model that ignores fugitive dust and uses baseline data from stations over 180 km away. The Air Report concludes that the EMSEZ will violate National Ambient Air Quality Standards (NAAQS) for SO2, NO2, and particulate matter (PM2.5 and PM10) even under a best-case scenario.
• The Health Impact Assessment (HIA) is accused of extensive plagiarism and lacking quantitative risk assessments. The CER claims the HIA underappreciates the toxicity of coal ash—containing carcinogens and neurotoxins—and fails to properly assess the impact of a proposed 3,000-hectare hazardous waste facility.
• Socio-economic benefits, including the projection of 21,000 jobs, are challenged as arbitrary and unsupported. The CER argues that the assessment fails to distinguish between temporary and permanent jobs, ignores the impact on existing agricultural and tourism livelihoods, and provides vague mitigation measures for pollution and carbon impacts.
• The EAP's own findings suggest that the project's negative environmental impacts likely outweigh its positive socio-economic benefits. The site is described as 'very sensitive' in terms of ecology and aquatic features, and the CER asserts that the project is inconsistent with the constitutional right to a healthy environment.

APA

Centre for Environmental Rights (2021). OBJECTIONS TO THE 7 DECEMBER 2020 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT [REVISION 01] 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/2022/03/gW-ELA-and-MEJCON-Revised-EMSEZ-EIA-objections-29.01.2021-1.pdf?x21779

Chicago

Centre for Environmental Rights. OBJECTIONS TO THE 7 DECEMBER 2020 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT [REVISION 01] OF THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE. 2021. https://cer.org.za/wp-content/uploads/2022/03/gW-ELA-and-MEJCON-Revised-EMSEZ-EIA-objections-29.01.2021-1.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=OBJECTIONS TO THE 7 DECEMBER 2020 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT [REVISION 01] OF THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE |date=29 January 2021 |url=https://cer.org.za/wp-content/uploads/2022/03/gW-ELA-and-MEJCON-Revised-EMSEZ-EIA-objections-29.01.2021-1.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2021objections, author = {{Centre for Environmental Rights}}, title = {{OBJECTIONS TO THE 7 DECEMBER 2020 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT [REVISION 01] OF THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE}}, publisher = {Centre for Environmental Rights}, year = {2021}, month = jan, url = {https://cer.org.za/wp-content/uploads/2022/03/gW-ELA-and-MEJCON-Revised-EMSEZ-EIA-objections-29.01.2021-1.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }