General Comments:

 We are living in the dying age of hydrocarbon fossil fuels. Economies are moving towards clean fuel motivated by global obligations to reduce greenhouse gas emissions and to meet the commitments to the Paris Climate accord. South Africa cannot ratify global treaties and then continue down a path of relying on coal fired power stations to meet our energy demands and extractive industries as a source of regional economic development.

In addition, we are working towards the Sustainable Development Goals which sees human rights at the centre of people centred development, this implies being cognisant of the natural resources available at our disposal, attaching value to them and engaging in broad consultative and educational processes to allow our people and communities to participate in visioning and building the future they want.

In his speech to the UN biodiversity meeting 30 September 2020 President Ramaphosa called for climate-friendly agriculture, sustainable food production. He stated “ In pursuit of sustainable development, our recovery strategies can, and should, strike a balance between environmental and economic imperatives. We need a holistic approach to achieving Sustainable Development Goal 15 on halting biodiversity loss.  As responsible global citizens, we need to change our behaviour and consumption patterns and integrate approaches to improve conservation of species and ecosystems. We need to adopt sustainable land management practices, restore degraded lands, implement sustainable food production models and develop more climate-friendly agriculture. There needs to be a shift away from economic models that value growth for growth’s sake towards a circular economy. We must engage with local communities, drawing on traditional knowledge, and promote the inclusion of women and indigenous populations in bioprospecting and other sectors.”

Objections / Issues raised in the EIA:

 The following points are the critical objections we have to the proposed MMSEZ and the underlying environmental viability of this project as outlined in the EIA:

  1. Lack of consultation with all interested and affected parties to map community resources and document a people’s driven vision for the region.
  2. Lack of sufficient water resources illustrated by the proposed plan to import water from Zimbabwe despite growing agricultural projects in Southern Zimbabwe putting increasing pressure on the water supply.
  3. The National Climate Change Adaptation Strategy (NCCAS) designed to meet our obligations in terms of the Paris Agreement on Climate Change implies a shift away from carbon-intensive investments and stopping the commissioning of additional coal fired power stations
  4. Special Economic Zones have not demonstrated revenue generation capacity for the state. Most are operating at well below capacity and constitute a net drain on the fiscus. The SEZ vehicle itself needs to be examined in terms of the regional objectives and the most effective mechanism to enable new empowering and uplifting social compacts where people are the primary engine for social development.
  5. The basis of the plan relies on unlocking the northern mineral belt as the catalyst but no alternatives have been proposed that could potentially create more jobs or change the socio-economic dynamic away from wage labour towards meaningful self-motivated work. Additional economic development opportunities such as the emerging cannabis industry need to be explored and the benefits presented so as to choose a progressive direction that meets the needs of a developmental state and the empowerment of our people.
  6. In the draft EIA’s own words “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.
  7. A cost needs to be ascribed to the pristine bushveld that the project will destroy and this needs to be offset against the minimum projected income of the project. Is the future going to value and respect biodiversity or is extractive mining and beneficiation going to set the tone for the next 50 years?
  8. Section 24 of the Constitutional Act states that ‘everyone has the right to an environment that is not harmful to their health or well‐being and to have the environment protected, for the benefit of present and future generations, through reasonable legislative and other measures, that prevents pollution and ecological degradation; promotes conservation; and secures ecologically sustainable development and use of natural resources while promoting justifiable economic and social development’. It does not make provision for offsets and other tools so as to allow the environment to be compromised.
  9. The potential investors have only agreed in principle to the project and the terms of the agreement especially with Chinese investors are not clear nor are their plans for labour. These issues need to be formalised in a transparent way with clear targets of employment


South Africa needs a broad consultative process to determine regional development plans not bureaucrats arbitrarily designating SEZ’s aligned to direct foreign investment objectives that are largely secret.

The dire straits of our fiscus demands that every Rand is accounted for and working towards a better life for all in a circular economy that builds wealth and local economies through a new inclusive social compact.

We need to proactively explore alternatives to the extraction-based development strategy analysed in this EIA focused on how to increase productivity in the agriculture and tourism sectors and start to decouple from the consumption of finite resources and start building natural and social capital in our communities.

Our people are our greatest resource, big capital spend projects need to be cognisant of their needs. Our economic reconstruction and recovery strategy need to focus on a new economy and new way of doing things that seeks to maximise renewable resources and develop human capacity. We hope that this EIA process leads to a more holistic approach to planning that is inclusive and representative of collective goals.