"Open Letter to Government Regarding the Status of Consideration of the Proposed Musina-Makhado Special Economic Zone (MMSEZ)", 17 March 2021

On 17 March 2021, Earthlife Africa Johannesburg, along with a number of community and other partners, made public a letter of concerns – submitted to the Department of Trade, Industry and Competition, and the Department of Environment, Forestry and Fishing – regarding the proposed Musina-Makhado Special Economic Zone (MMSEZ) in Limpopo Province. Some of the key issues relate to the lack of meaningful public engagement, with communities feeling left out of the decision-making process for a project which will severely affect them. Find the complete letter below, for more information, with the list of partners who have signed on. [...]

Dear Minister

We write as organisations and individuals (listed below) concerned about the proposed Musina-Makhado Special Economic Zone (MMSEZ) being promoted by the Limpopo Provincial Premier and government. This is an urgent supplement to our engagement with available public processes, in particular the Environmental Impact Assessment (EIA) being undertaken for the Musina-Makhado SEZ (SOC) Ltd, conducted under the authority of: Limpopo Economic Development, Environment and Tourism (LEDET).

We have questions on several issues which fall outside the scope of any available engagement process (that we are aware of), but are of vital interest to potentially affected parties and urgent relevance to other development plans and on-going policy elaboration, inter alia enhancing South Africa’s Nationally Determined Contribution under the Paris Agreement, and the sustainable development prospects for competitive participation in international supply chains for the minerals required for a zero-carbon global economy.

We choose to address both Ministers as it is not clear how big-picture issues are to be addressed or the extent to which SEZ legislation may be supportive of an integrated assessment of the over-all value proposition, which is essential and not addressed under the incremental approach being taken to environmental impact assessment. We are also concerned about potential conflicts of interest for Provincial authorities, with LEDET being responsible for an objective assessment of the proposition’s socio-economic merits (under the EIA), while the Limpopo Economic Development Agency (LEDA) is championing the MMSEZ.

With regard to understanding the potential national value of this mega-project, we request access to documentation addressing the roles and responsibilities of the various parties, including the Memorandum of Understanding between national and provincial government – particularly any provisions for assessment of projected job creation and net socio-economic benefit – and an overview of any public engagement processes pertaining to the MMSEZ that are or will be overseen by national government, i.e. DEFF or DTIC.

We further request access to or details of the currently applicable Operator’s Permit, such as was signed by Rob Davies as DTI Minister in 2017, and the terms of appointment of the operator.

From information available to date, it is clear that prospective water supply options “being considered” by Limpopo Province have not been meaningfully assessed and remain highly speculative. In this regard we’d welcome any information on any engagement or communication by national government with the regional body having oversight of the whole Limpopo River catchment area – the Limpopo Basin Commission (LIMCOM) – and/or with the Limpopo North Catchment Management Agency.

We submit that any new minerals development and beneficiation projects or infrastructure investment drive should not be premised on expanding coal value chains, either nationally or internationally, nor in any way increase South Africa’s dependence on or combustion of coal; rather it should be aligned with long-term sustainability and a just transition to a zero-carbon economy.

We trust you will give consideration to the concerns we have raised, and request that you enable provision of the documentation and information requested above. We further respectfully request an early indication of your intentions in this regard.

Organisations and individuals who have signed on to the letter:

350Africa.org – Glen Tyler-Davies –

Africa Climate Reality Project (ACRP) – Amy Giliam –

African Centre for Citizenship and Democracy (UWC) – Prof Lisa Thompson

All Rise – Kirsten Youens

Alternative Information and Development Centre (AIDC) – Dominic Brown

BirdLife South Africa – Dr Melissa Lewis

Batlhabine Foundation – Mashile Phalane

Centre for Applied Legal Studies – (CALS – Wits) – Louis Snyman

Centre for Environmental Rights NPC – Michelle Koyama

Earthlife Africa Jhb – Thabo Sibeko

Greenpeace Africa – Nhlanhla Sibisi

groundWork – David Hallowes

Mining Affected Communities United in Action (MACUA) – Meshack Mbangula

Mining and Environmental Justice Community Network of South Africa (MEJCON SA)

Nkwane Elton Thobejane

NoToSEZ.org campaign   Kerry Liebenberg –

Project 90 by 2030 – Richard Halsey

South African Faith Communities Environment Institute (SAFCEI) – Francesca de Gasparis

Save Our Limpopo Valley Environment (SOLVE) – Wally Schultz

South Durban Community Environmental Alliance (SDCEA) – Sherelee Odayar

The Philip Herd Nature Reserve – Lauren Liebenberg

Wildlife and Environment Society of SA (WESSA) – Dr Cathy Dzerefos

WoMin Africa Alliance – Caroline Ntaopane –

WWF-SA – James Reeler –

Brandon Abdinor – lawyer –

Gillian Hamilton

Dr Victor Munnik

Hazel Shirinda  –  Limpopo Province

Richard Worthington