Centre for Environmental Rights – Advancing Environmental Rights in South Africa

The Life After Coal Campaign welcomes the temporary halt called by the Limpopo provincial government on the controversial and harmful Musina Makhado Energy and Metallurgical Special Economic Zone (EMSEZ) project.  According to a letter posted on appointed environmental consultants Deltabec’s website on 15 March 2021, the Limpopo Economic Development Environment and Tourism Department (LEDET) notified the project proponent, the Limpopo Economic Development Agency (LEDA), that it could not proceed with the EMSEZ project unless many gaps in Environmental Impact Assessment (EIA) were addressed.

Some of the gaps identified by LEDET indicated serious flaws in the EIA process, including public participation not being conducted in local languages, missing information related to the project’s needed water and energy supply, as well as the absence of identified alternative sites for the project to be developed (a legal requirement).

“It is important that public consultation be conducted in local languages so that the impacted communities are fully informed from the beginning on how the project could affect them.  Communities also need notice of meetings well in advance as many have to travel far for these meetings. Unfortunately, these public consultations were seriously flawed from the beginning in both of these respects”, says Makoma Lekalakala, head of Earthlife Africa, who has been a vocal opponent of the EMSEZ project.

The proposed EMSEZ project includes heavy industries (like ferrochrome, ferromanganese, steel and cement plants), and a 3300 MW coal-fired power station, with a price tag of R247.8 billion.

The Life After Coal campaign and the Mining and Environmental Justice Community Network of South Africa (MEJCON-SA), had submitted comprehensive objections to the EIA for the clearing of the proposed site. A number of concerned community-based and civil society groups, have been contesting the environmental authorisation for the project for the past few years. The grounds for opposition include concerns around the significant climate and water impacts this proposed water and emission-intensive project will have for people and the notoriously water-scarce surrounding area.

The EMSEZ project is of particular concern to the coalition and surrounding communities as it will compete with 18 million people along the Limpopo Catchment in Botswana, Mozambique, South Africa and Zimbabwe for water. “Despite water impacts on our neighbouring nations, no public participation has been held with the water users in those countries, nor the Limpopo Water Commission, which is a transboundary water catchment management agency, to manage the shared water resources,” says Michelle Koyama, attorney at the Centre for Environmental Rights.

An expert report submitted by LEDA reveals that the project would emit greenhouse gases that would represent 10-16% of the South Africa’s entire carbon budget. Undoubtedly this will adversely impact South Africa’s climate obligations. The project’s climate change impact assessment warns that the coal fired power station may become a stranded asset.  Despite this, investors in EMSEZ – the South African Energy Metallurgical Base (Pty) Ltd – see no need for adequately seeking alternative methods for curbing its climate change impacts.

LEDET has requested the project proponent LEDA to develop a further plan of action (with timelines) to address the identified gaps, and to conduct further public participation with focus groups. However, there is limited time to address these fatal flaws, since according to the EIA process entrenched in law, LEDET has to make a decision by 20 May 2021.

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