Public Comment - further detail of objections to be provided as addendum to my comment

I 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 then has the EAP recommended approval?

I OBJECT TO : The governance failure inherent in this plan. 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 for decision making purposes. Given its far-reaching impacts on the environment, water resources, global climate change and human rights, the EMSEZ development is a matter of national and international importance. Additionally, an independent investigation should be made of the "unsolicited R12.3Bn quote" to build the "Musina Dam".

I OBJECT TO : allowing the EMSEZ to go ahead on the basis of the carbon emissions it will produce. I strenuously object to a 90+30 year deal.

The reduction of South Africa’s Carbon emissions is not only an international obligation but a Constitutional imperative. We submit that allowing the EMSEZ to proceed 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. This is on the basis of the immense climate change impacts that the EMSEZ will have. By their scale and nature the proposed National Environmental Act listed activities require a comprehensive and accurate assessment.

I STRONGLY OBJECT TO : the lack of comprehensive assessment on the impact on water resources and all other water-users in a highly water stressed region of supplying the vast water needs for EMSEZ.

I further strongly object to the proposal that 95% of the long term water needs will be supplied as “raw water” from the so-called “Musina Dam” that is to be built and fed with Limpopo River water without a proper assessment of whether this is feasible or fair.

The appointed water specialists recommend completing this assessment as “mitigation”. The EAP concludes that LEDET should only grant approval of the project provided a sustainable water supply is secured and “guaranteed” . A detailed assessment the plan to meet those actual requirements through damming the Sand River and developing the "Eastern aquifer" MUST be undertaken and made available so that Interested and Affected Parties; authorities and relevant decision-makers can properly consider these significant impacts. The conditions for approval of the project set by the EA have NOT been met in this fundamental respect and the EMSEZ proposal should be rejected on this basis (that the water is not guaranteed and the environmental consequences have not been assessed and the EMPR contains no reference to these dams at all).

WE STRENOUSLY OBJECT TO : Allowing the EMSEZ to go ahead on assumption that 2 x 200 Mn cubic meter dams will be built in the Sand River. One of which, the so-called “Musina Dam” will supply 95% of the entire EMSEZ long-term water needs.There MUST be a comprehensive and accurate assessment of the environmental impacts of the proposed damming activities so the interested and affected parties can have opportunity to comment.

IF 95% OF THE WATER SUPPLY IS TO COME FROM THE "MUSINA DAM", THEN WHY ARE DAMS EXCLUDED FROM BOTH THE EIA & THE ENVIRONMENTAL MANAGEMENT PLAN? The so-called "Musina Dam” is an unbuilt “concept” dam which is not once mentioned in the Environmental Management Plan and is not shown as part of either of the SEZ site plans, yet an “unsolicited” quote to build two of these dams for R25Bn has been received from an undisclosed source. It is also concluded that these dams “protect the interests of the Zimbabweans and Mozambiquans”, but no explanation of how it protects their interests (nor how this affects the interests of the people of South Africa!) is offered. There is no assessment in the EIA on the feasibility, environmental impact or other consequences of building these dams – either on the downstream water users and aquifers or on the land where the dams will be built.

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


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