Our Primary Objections

My Objection to the Proposed EMSEZ

WE OBJECT TO : Allowing the project to go ahead without an independent national review of the EIA conclusions. From the report's headline "overall conclusions"...."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.". Why has the EAP recommended approval?

WE OBJECT TO : The governance of this proposal. We assert it does not protect the long term interests of the citizens of Mozambique, Botswana, Zimbabwe or South Africa. LEDET is the proposer of the SEZ project and has also been appointed as the competent authority. Given its far-reaching environmental and human rights impacts. The EMSEZ and the industrial development plans associated with it are a matter of national and international importance. WE OBJECT TO : allowing the EMSEZ to go ahead on the basis of carbon emissions. WE strenuously object to a 90+30 year deal. The reduction of South Africa’s Carbon emissions is not merely an international obligation but a Constitutional imperative. We submit that allowing the EMSEZ to go ahead would be a flagrant violation of inter alia the Constitutional rights: to human dignity; to life; and to an environment not harmful to health or well-being and to have the environment protected for the benefit of present and future generations on the basis of the immense climate change impacts that the EMSEZ will have. which must be a comprehensive and accurate assessment of the climate change impacts of the proposed NEMA activities. WE STRONGLY OBJECT TO : the lack of comprehensive assessment on the impact of the water supply for EMSEZ in a highly water stressed region. The EAP recommends that there should be “guaranteed water” for EMSEZ before approving the project. 95% of the long term water needs will be supplied as “raw water from the Musina Dam”. ​ This dam is to be filled with Limpopo water – yet no assessment has been made that the water is in fact available. The water specialists recommend doing this assessment as mitigation. This information MUST be made available so that Interested and Affected Parties. authorities and relevant decision- makers can properly consider these significant impacts and provide appropriate comments. The conditions for approval of the project set by the EA are NOT met for this source and the EMSEZ proposal should be rejected on this basis (the water is not guaranteed and the environmental consequences have not been assessed and the EMPr contains no reference to these dams) IF 95% OF THE WATER SUPPLY COMES FROM THE "MUSINA DAM", WHY ARE THE DAMS IGNORED IN BOTH THE EIA & THE MANAGEMENT PLAN? WE STRENOUSLY OBJECT TO : allowing the EMSEZ to go ahead with the assumption that 2 x 200 Mn cubic meter dams can be built in the Sand River with no environmental assessment of these. The "Musina Dam” is an unbuilt “concept” dam which is not once mentioned in the Environmental Management Plan and is not mentioned as part of either of the SEZ sites. ​Yet there is a “unsolicited” quote to build two of these dams for R25Bn from an unknown source.​ It is also concluded that these dams “protect the interests of the Zimbabweans and Mozambiquans” – but no explanation of how taking the Limpopo water protects their interests. ​ There is no assessment in the EIA on the environmental impact or the consequences of building these dams – either on the downstream water users and acquifers or on the land where the dams will be built.​There must be a comprehensive and accurate assessment of the environmental impacts of the proposed daming activities so the interested and affected parties can have opportunity to comment.

I object to the EAP water specialist's assessment that the risk reduces if a water study is undertaken of the water in the Limpopo. The study in itself will not reduce the risk. The assessor has made a critical error in their scientific assessment and the water risk remains as "high impact" and "negative.

WETLANDS: Multiple wetlands are located across the eight farms, including seeps, flats, valley‐bottom wetlands and channeled valley‐bottom wetlands. Limited desktop study. Major impact, no room for mitigation, only offsets;

PROTECTED AREAS: UNESCO Vhembe Biosphere Reserve; National Parks(Kruger national Park, Mapungupwe national Park); Formal Protected Areas (Baobab Protected Reserve; Musina, Honnet, Nwanedi, Nzhelele, Happy Rest and Langjan Nature Reserve; Informal Protected Areas; National Protected Areas Expansion Strategy(NPAES) Focus Areas (Blouberg Langjan National Protected Areas); and Private Nature Reserves (Averal, Nzhlelele); Critical Biodiversity area 2; Ecological Corridor Network; Important Bird Area nearby;

CLIMATE CHANGE: High risk: estimated 1 billion tonnes of CO2 equivalent emission over its lifetime, which is about 10-16% of SA’s total carbon budget annually (figures vary in various pages of the report). Mitigation will not alter the impact the GHG on climate change impacts in terms of probability, extent or duration of the risks. Some of the threats include temperature increase related crop loss – food insecurity for the communities in the region, operation of SEZ due to lack of water; floods; endemic biota decline; worsen socio-economic impacts for the Vhembe community;

HERITAGE: stone age materials; burial sites;

FARMING: potential impact to 689000ha agricultural and grazing land due from water competition, pollution, air pollution, water contamination;

AIR QUALITY: possible pollution from PM, Manganese, Hexavalent Chromium, Sulphur Dioxide, Hydrogen Sulphide, Carbon Dioxidde, Oxides of Nitrogen;

TOURISM AND FOOD SECURITY: project may impact tourism (many nature reserves in the area) in the region due noise, aesthetics, pollution from various industries in the region etc. Loss of agricultural land due to more mine prospectors coming into the region;

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