The Sham of the Public Participation Process on the Environmental Impact Assessment for the Musina-Makhado Special Economic Zone (SEZ) 14-19 September 2020

Meshack Mbangula, Hazel Shirinda and Lisa Thompson

The Environmental Impact Assessment (EIA) of the Musina Makhado Special Economic Zone (SEZ) echoes the promises made by government backed mega projects in the Global South. Multinational companies, endorsed by governments for the fiscal kickbacks, commit to alleviate people’s poverty where the primary goal is to shift their need for Africa’s rich mineral resources and to offset their national carbon footprint. The Musina Makhado SEZ, or MMSEZ as it is now called by government, is a perfect case in point. The SEZ will be the first in South Africa to be operated by a foreign (Chinese) company, Hoi Mor Shenzhen. This will mean an unprecedented level of foreign control over the SEZ. To make matters worse, of the proposed industries in the metallurgical cluster, nearly all of them are carbon intensive, environmentally destructive and a threat to the livelihoods of communities in the medium term due to the health implications of such large CO2 emitters

The high-level EIA, as it is called, was completed by the Delta Built Environment Consortium (Delta BEC) and made public in September 2020. While admitting the environmentally harmful nature of the SEZ, it is still a self-justificatory document. The EIA assessment glosses over the endemic water scarcity issues in the Limpopo Valley stating “… if insufficient water is available in the catchment, and the social and economic opportunities offered by the SEZ operation are sufficiently attractive, additional water may be brought in from a neighbouring catchment”.

Although not unexpected, but still shocking in its lack of community buy-in, is the public participation process that has just taken place. All large-scale developmental initiatives, especially those with huge community impacts, should abide by the principle of “free, prior and informed consent (FPIC)” so that those affected communities can engage from an informed base. For example, to advertise a public participation process in a remote area like Limpopo Province, it is blatantly obvious that to advertise such a process in newspapers is ridiculous. Communities in poor remoter areas (most of the province) do not have access to newspapers. A quick vox pop and interviews with communities near the MMSEZ (especially the Mudemele, the closest to the SEZ) show that most communities did not know of the public participation process across the spectrum of race, age and gender. The meeting in Louis Trichardt was attended by exactly 15 people.

Governments worldwide, including South Africa, work to ensure that EIA processes events appear to be carefully orchestrated so that public dissent is kept to a minimum.

There are also many ways of “massaging” EIA processes to ensure that dissent is minimized. One easy method is to make sure the general public are not informed of the meetings by using the absolute basic requirements of the EIA PP process (in this case advertising in only 2 newspapers, 1 of which is not widely read in the Musina-Makhado area). Another way of massaging the process is to split the EIA process up so that within the SEZ different industries will require separate EIAs. This is exactly the case with Musina

Makhado. The current “high level” EIA, as it is called, is a predominantly site clearing process of getting approval from LEDET. The carbon intensive aspects of the proposed projects within the Zone would all require separate EIAs.

Each project will also have to apply for a water use licence. While the EIA draws attention to the fact that the province is water scarce, the plans to alleviate water scarcity, as outlined in the EIA are clearly inadequate. The EIA states the plan to use what LEDA call surplus water capacity, but water scarcity is endemic to the region, and a burgeoning of coal mining in the area, together with commercial farming, will not help to allay the situation.

The MMSEZ will undoubtedly cause a radical decrease in carbon sequestration in and around the zone. The EIA proposes to uproot and transplant some 100 000 mature trees growing in arid terrain. The suggestion is absurd even to the layperson, but from an environmental science point of view it is just plain stupid science. The flora and fauna of the area will be destroyed and the ecological balance of the Limpopo Valley changed forever. Is this farewell to the Valley known for its majestic trees and pristine ecology?


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