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Details of the water supply proposal

Updated: Oct 22, 2020

1. BIG, DIRTY & THIRSTY, THE EMSEZ IS BEING BULLDOZED THROUGH THE APPROVALS PROCESS Despite the mind-boggling scale of the proposed noxious industrial development and the consequent severe impacts on national water and other natural resources, climate, biodiversity loss, protected areas, agriculture and tourism sectors, pollution of air, water and soil and hazards to human health, no proper feasibility study and no proper assessment of the environmental impacts has ever been undertaken:  Instead, the MM-SEZ has been designated, the operator license awarded to an opaque Chinese entity, and undisclosed Chinese investors have reportedly committed billions - and now the draft EIA report has been published recommending authorization, even though the actual scope of the  assessment is limited to site clearance of the southern site, for the purported reason that full impact cannot be assessed, because each of the planned industrial plants, mines and mega dams to be built on the Limpopo River will need to be separately assessed after the EMSEZ is approved.  We object to the fatally flawed EIA process and consequently invalid recommendation by the Environmental Assesment Practioner (EAP) in the DEIR that the EMSEZ be authorised. The DEIR must be be withdrawn pending a comprehensive Strategic Environmental Assessment (SEA) as argued for by the Centre for Environmental Rights, acting for groundWork and Earthlife Africa, and we reject Minister Barbara Creecy's claim that there is "no legal requirement for an SEA to be conducted at this time".

2. THE VAMPIRES IN THE BLOOD-BANK Under the terms of the signed operator agreement, complete control of the land and the mega industrial development project has been surrendered for an effective 120 years to an opaque Chinese company called Shenzhen Hoimor Resources Holding Company with a dubious reputation, to whom all responsibility including for environmental protection, has been transferred - something that appears contrary to its authority, its competence and its own interests. This deal with its vast ramifications for South Africa was signed by a small, under-resourced and conflicted provincial government department, the Limpopo Department of Economic Development, Environment and Tourism, LEDET, which has been given decision-making authority in respect of the proposed EMSEZ. It is also empowered to grant environmental authorisation, which will determine whether the project goes ahead, despite the fact that it also acts as the project's sponsor. We believe that the operator agreement amounts to a total abrogation of government's duty to protect South Africa's interests. We object to LEDET's designation as the competent authority on the grounds that it lacks the jurisdiction and is conflicted in the matter. The DEFF must assume responsibility as provided for in NEMA, 1998 S24C(2)(d))iii).

3. COAL-FIRED DEFIANCE The proposed EMSEZ - including the 3,300MW coal-fired power station that will be built to power a staggering number of industrial-scale smelting furnaces, together with a raft of new coal and other mines that will be built to feed it - will essentially be a coal-fired hell. The greenhouse gas emissions that will be generated, wholly inadequately assessed but estimated at 1 billion tonnes of CO2 over its lifetime and about 10-16% of South Africa's total carbon budget annually, will constitute a flagrant violation of inter alia South Africa's commitments under the Paris Agreement and government's Constitutional obligations to reduce GHG emissions and the impacts of global warming. We object to the wholly inadequate assessment of the climate impact of the EMSEZ. An accurate estimation of the amount and type of fuels that will be consumed by each component of the planned EMSEZ project annually during operation and over its lifetime, the annual emissions of carbon-dioxide and other air pollutants including mercury and other heavy metals, and the climate impact along with associated environmental, economic and social costs cumulatively from the EMSEZ and the raft of new mines that will supply it, must be undertaken.

4. THE PLUNDER OF LIMPOPO'S WATER Despite the fact that the Limpopo is severely water-stressed, the assessment of the actual water resources required for the operation of the EMSEZ industrial complex in the DEIR is crude and grossly inadequate. Even the estimates given however, are gob-smacking - at 110million cubic meters per annum, equivalent to the water use of 1.43 million people. And yet the plans to supply those needs, as well as the impact assessment of these plans are even more ill-considered: Essentially, buried in Annexure U of the 878page draft EIA report is a muddy explanation of how 95% of the water requirements will be met by building a mega dam on the already over-allocated Limpopo River at the confluence of the Sand River on the Maremani Nature Reserve - the 200Mm3/a "Musina Dam" - close to the northern site, to capture the annual flood waters of the Limpopo. The assessment of the impact of this water capture on downstream water-users in South Africa and Mozambique is limited to a reference to the averted loss of life and flood damage. The Integrated Water Services Report makes a further reference to additional plans to tap the Zhove dam in Zimbabwe; build a second 200Mn3/a on the Sand River and to siphon the "Eastern Alluvial Aquifer" in the event that the water in the Musina Dam proves insufficient. The series of dams are excluded from the scope of the draft EIA report completely, and the Musina Dam is mentioned not once in the 251-page EMPr. Curiously there is a reference to a R25Bn "unsolicited" quote to build the dam. We object to the fundamentally flawed analysis in the DEIR of water needs of the EMSEZ and water availability and the unjust plan to use the Limpopo River water without proper assessment of the impacts. An full review in consultation with all affected water-users of the Limpopo Catchment Area Water Management Strategy must be urgently commissioned.

5. WHOSE GAIN AT WHOSE EXPENSE? The real costs and benefits of the proposed EM SEZ have not been properly accounted for and are highly skewed in their distribution. The draft EIA report itself baldly states, "The proposed project is considered to have an overall high negative environmental impact, with low‐medium positive social and economic impact due to the site being very sensitive in terms of environmental features (ecology, aquatic features, etc.) and the introduction to possible greenhouse gases, air quality, noxious gases, climate change impacts, etc., all which will have a negative impact on the environment and surrounding areas. On the other side the equation, the benefits of the project as set out in the EIA are vague and unsubstantiated. Although the DEIR argues for the project on the basis of export-driven economic growth, it also mentions the tax incentives on offer inside a SEZ to attract FDI, however, it fails to disclose the extent of the corporate income; VAT; customs and duty-tax relief granted to the operator (all deductions off South Africa's bottom-line). It provides no firm commitments in terms of job creation or supplier contracts for local businesses. Indeed, it is not at all clear from the DEIR how South Africa really benefits from the minerals extraction that will happen on our soil, using our coal, our water and contaminating our environment: On the face if it, the exporter is the foreign-owned entity that holds the rights. It looks rather as if China's gain is at our and the planet's expense. We object to any authorisation of the EMSEZ being considered given the DEIR's stated conclusion that "The potential negative impacts of the development on the natural, tourism, and agricultural environment of the site and the region may in all likelihood, outweigh the identified positive impacts associated with the potential social and economic development benefits in the longer term." The authorisation must be denied on the grounds that the applicant (who is also the adjudicating authority) cannot reasonably comply with the conditions of authorisation set out in the DEIR, including with respect to guaranteeing a sustainable water supply.


Rhttp://www.mmsez.co.zaef. Appendix C : "surrounding land owners"




3. REFERENCES


Ref. Page 25 of DEIR Appendix U: "Integrated Water Services report" section 10. titled "Specific Supply Plan"


a) Southern Site - Long term


Ref 10.2.3.4. Long Term (Southern Site) Specific Supply Plan of the INTEGRATED WATER SERVICES REPORT page 28

PLUS (main) DRAFT EIA REPORT impact assessment specialist findings S6.2 Water: 6.2.1.3


The proposal : Build the "Musina Dam" to harvest the Limpopo flood water


Capacity: (ref 3 below) 200Mm3/a

Location : (image 13) The map which they refer to in the table as “image reference 17” below shows a pin on the Njelele and the pins on the SEZ site.

(ref 3) Just south of the confluence of the Sand River with the Limpopo River; approximately at the position of the road bridge that link the western and eastern banks of the Sand River on the “border road”.

Specifications Height: 39 m - Length: 950 m (ref 3)

Supply out (where the dam is sending stored water): (ref 1)

74.49Mm3/a to Southern site and 15Mm3/a to Northern site

Note : 74.49/80Mn3/a = 93% of the long term needs for southern from this dam

Cost (ref 17) R12.3Bn

Supply in: (ref 3 below)

170Mm3/a Limpopo (20% of its annual flood) and 30Mm3/a Sand

Mitigation recommended by specialist "A full mainstem hydrological study”

Outcome of doing this study:

Apparently reduces the “high impact negative” risk from high to medium (HOW).

Is this supply source considered “guaranteed” to meet the EIA “GO” conditions

No, because the amount of flood water plus alluvial water is UNKNOWN.

Environmental Consequences assessed:

None

– in the 250 page Environmental management plan the Sand River dams and the consequences on this river or the Limpopo downstream are not mentioned a single time

- The recommended “full stem hydrological study of the Limpopo” is not mentioned in the 251 page EMPr

- The land use change of changing from pristine bush to mega dams is not mentioned in the 858 page EIA.

- The I&APs have not been notified



ref 12. INTEGRATED WATER SERVICES REPORT, image 13; and 6-151 in EIA draft page 685



References from EIA :


ref 1. INTEGRATED WATER SERVICES REPORT, chapter 10 Specific Supply Plan section 10.2.3.4. page 28 Long Term (Southern Site)


"The long-term supply volume will be reached with the completion of the Musina Dam System, with an anticipated yield of 200 Mm3/a.


The 80 Mm3/a water required - A part supply from the Musina Dam of 74.49 Mm3/a.


Note : 74.49/80 = 93% of the long term needs for southern will come from this dam




ref 11 EIA ref DRAFT EIA impact assessment specialist findings section 6.2 Water: 6.2.1.3 page 684


ref 3. INTEGRATED WATER SERVICES REPORT - title "flood harvesting" Page 21 Section 9.1.6 of the



There will be relied on Limpopo flood water to fill 85% of the capacity of the dam, while the remaining 15% will serve to receive possible flood water from the Sand River"


Note : 85%=170M3m and 15% is 30M3m from the sand river

.

"The volume of flood water that pass Musina is estimated to be as high a 2,000 Mm3/a. It is proposed that a volume of this flood water is harvested, pumped into, and stored in dams that are constructed on suitable confluent steams to the Limpopo River. A single- or a series of dams can be provided to store the required volume of water. "




"Position of the proposed dam wall: Just south of the confluence of the Sand River with the Limpopo River; approximately at the position of the road bridge that link the western and eastern banks of the Sand River on the “border road”. - Height: 39 m - Length: 950 m - Storing volume: In excess of 200 Mme/a -




ref 4 EIA ref INTEGRATED WATER SERVICES REPORT - title "flood harvesting" Page 22 Section 9.1.6


Unsolicited quote

A proposal was rendered to the authorities for the construction of the “Musina Dam” on the lower section of the Sand River.


An unsolicited bid for the project, The detail of the submission and the party is not presented in this proposal. It will be subjected to the various required public processes as required.


EIA ref INTEGRATED WATER SERVICES REPORT - title "flood harvesting" Page 22 Section 9.1.6



The "advantage" for Mozambique

The considered perceived advantages pertaining to this proposal includes the following: - The water to be harvested is considered to be unallocated. After passing the most of it will flow down the river, through Mozambique and into the sea. - This may contribute towards the kerbing of flood events on the floodplains in Mozambique and may lead to reducing flood damage and loss of life.


EIA ref INTEGRATED WATER SERVICES REPORT - title "flood harvesting" Page 22 Section 9.1.6




Mitigating the risk

Risk pertaining to this proposal will be addressed through the following:

- Technical feasibility and cost: Feasibility studies to aid in further decision making.

- Consensus flood figures for the Limpopo: DWS will require extensive hydrological studies on the whole Limpopo River, including studies of the contributing Botswana and Zimbabwe catchment areas.


EIA ref 4 INTEGRATED WATER SERVICES REPORT - title "flood harvesting" Page 22 Section 9.1.6


ref 10 Page v1 of EIA executive summary : impact assessment

Moves the risk of water from high to medium IF the mitigation is undertsaked. The mitigation is the full mainstem hydroglogical study



ref 14. DRAFT EIA 6.2.13.4 titled "impact assessment of the water" - written by water specialist




ref 17 page 48 INTEGRATED WATER SERVICES REPORT, chapter 12, conceptual capital cost





b) Southern site short / medium term needs

a) "The department of water will provide 30Mm3/a"

Page 37 section 2.1.6.2 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME



b) or alternative "guaranteed solution" is to "build a smaller Dam in the Sand river"

A separate scenario is developed as contingency plan for the event that physical evidence may proof the eastern wellfield not to be feasible. A volume of flood water can be harvested and stored off-channel for preliminary use, for the period before the completion of the permanent supply volume.


Build a smaller dam on the Sand river

Capacity ref 6 between 10 Mm3/a and 30 Mm3/a

Location ref 6 : "described as "same principle" as the larger dam, so assume same location

Cost : ref 6 It is anticipated that the cost associated with this option will not exceed the potential aquifer development cost, to the contrary, it may be much lower,

References from EIA :


ref 6 EIA ref INTEGRATED WATER SERVICES REPORT - title "infrastructure" Page 37 Section 11.2.3.2

"The principle for long term supply is the harvesting of flood water from the Limpopo and the offchannel storage thereof for use during the year.


It is worth wile to consider a smaller application of the same principle to serve the medium-term needs with between 10 Mm3/a and 30 Mm3/a as target. Ideally this should then be serviced with pump- and pipeline infrastructure that is planned and constructed as modular components of the final infrastructure. It is anticipated that the cost associated with this option will not exceed the potential aquifer development cost, to the contrary, it may be much lower, depending on the locality of an applicable site. This option is currently under investigation.





c) Northern site needs

(i) first option is to dig wells in the Limpopo in front of Maremani reserve

"Build a new Eastern wellfield in the Limpopo Alluvial Aquifer"

Capacity : 20Mm3/a

Location Limpopo alluvial wellfield east of the Limpopo – Sand River confluence

Downstream to the Sand River confluence, on the farms Vryheid 8 MT, Bokveld 12 MT and Malala Hoek 13 MT

Cost R645Mn (ref 18)

Mitigation recommended by specialist "There is no scientific basis to assume this water exists", So mitigation is a "A full mainstem hydrological study is required... to substantiate the extent of available water in the limpopo acquifer to take up without infringing the allocation rights of others”

Their assessment of the Outcome of doing this study:

Apparently reduces the “high impact negative” risk from high to medium (HOW).

Is this supply source considered “guaranteed” to meet the EIA “GO” conditions

NO guarantee of this supply. "a zero supply scenario from this source should also be considered to clarify the impact on its development”

Environmental Consequences assessed:

None








EIA REFERENCES


ref 8 EIA ref INTEGRATED WATER SERVICES REPORT - title "infrastructure" Page 37 Section 11.2.3


“It is anticipated that large volumes of water may still be available in the Limpopo Alluvial Aquifer. It is anticipated that a further 20 Mm3/a may be harvested from this source downstream to the Sand River confluence, on the farms Vryheid 8 MT, Bokveld 12 MT and Malala Hoek 13 MT.”


There are no current scientific grounds for this assumption. "A full mainstem hydrological study is required... to substantiate the extent of available water in the limpopo acquifer to take up without infringing the allocation rights of others”

It must therefore be noted that a zero-supply scenario from this resource should also be considered to clarify the impact of it on the development.







Additional yield from the envisaged Limpopo alluvial wellfield east of the Limpopo – Sand River confluence. Of the anticipated 20 Mm3/a yield of this resource, 14.89 Mm3/a will be required to meet the full long-term demand.


Page 50

“Taking Water from a further Eastern Wellfield from the Limpopo Alluvial Aquifer between the Sand River confluence and the eastern extent of the farm Malala Hoek 20 Mm3/a

ref 5 EIA ref INTEGRATED WATER SERVICES REPORT - title "unused water" Page 21 Section 9.1.4


Specific data from the official WARMS database ….. It also indicates that a considerable volume of water is authorized from the Limpopo along the farms Vryheid, Bokveld and Malala Hoek, just east of the Sand River confluence. As will be indicated later, it is envisaged that approximately 20 Mm3/a will be drawn from this 13 km stretch of Limpopo Alluvial Aquifer to meet the SEZ requirements.







ref 5 EIA ref INTEGRATED WATER SERVICES REPORT - title "unused water" Page 21 Section 9.1.4





The recommended “full stem hydrological study of the Limpopo” is not mentioned in the 251 page EMPr



ref 18 EIA ref INTEGRATED WATER SERVICES REPORT - title "conceptual capital cost" Page 47 Section 12




(ii) or to guarantee supply, Harvest the Limpopo flood water in a smaller dam

A separate scenario is developed as contingency plan for the event that physical evidence may proof the eastern wellfield not to be feasible. A volume of flood water can be harvested and stored off-channel for preliminary use, for the period before the completion of the permanent supply volume.


Build a smaller dam on the Sand river ref 6

Capacity between 10 Mm3/a and 30 Mm3/a

Location : "described as "same principle" as the larger dam, so assume same location

Cost : It is anticipated that the cost associated with this option will not exceed the potential aquifer development cost, to the contrary, it may be much lower,




4. BEYOND EMSEZ NEEDS


Build a second 200Mnm3/a dam on the Sand river

Capacity : 200 Mm3/a of stored Limpopo flood water

Location : upstream in the Sand River, just upstream of the current R508 (linking Musina and Tshipise) road bridge over the Sand River

Cost : assume the same R12.3Bn

Supply out: Free to sell inland

Supply in: Described only as harvesting Limpopo flood. Musina Dam is described as taking 20% of the flood water therefore this could be assumed to be a further 20%.




EIA REFERENCES


Section INTEGRATED WATER SERVICES REPORT 11.3.4.

Beyond Reaching Long Term Supply :

The conceptual Musina Dam is envisaged to have a yield of 180 Mm3/a.

Only 74.39 of this will be required for this Musina and MM SEZ direct requirements, with in excess of 100 Mm3/a available for the regional water balance.

The second dam upstream in the Sand River, may contribute another envisaged 200 Mm3/a of stored Limpopo flood water to the balance

Page 22 INTEGRATED WATER SERVICES REPORT: 9.1.6. Flood Harvesting and Off Channel Storage

To possibly extend to this storage capacity, a second dam of approximate equal capacity can be constructed upstream in the Sand River, just upstream of the current R508 (linking Musina and Tshipise) road bridge over the Sand River. The advantage locked in this supply option is that it can provide water far beyond the envisaged Musina and MM SEZ requirements, to the extent that water may be available from it for distribution further inland.





Construction phase


Need 13.9Mn cubic meters

Rest not evaluated



---------------------


5. SUMMARY OF OVERALL WATER DEMAND


1. Construction phase 13.9 mn cubic meters (13Mm3/a)



2. Northern site long term 20Mn cubic per annum (20Mm3/a)






3. Southern site long term

“123million cubic meters per annum” page 36 of EMPr vs normal allocation from ground and surface :0.37 (123Mm3/a)

The water Appendix only shows a long term need of 80

ref 16 NTEGRATED WATER SERVICES REPORT, chapter 11 Infrastructure section 11.3.3.2 page 45






Water demand until 2040

7.2.2. In the internal master plan:

The water demand for the MMSEZ as well as new mines in the area and the growth of the two municipalities involved are presented in Table 7 below. page 22 of the internal master plan appendix 0804_EMSEZ Master Planning Extract Write Up _29.07.2020




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