Africa Wild

So who gets the Spin off from the Tenders

Why has Limpopo dumped its biodiversity protection plan into a dark hole?


The largest baobab tree in the Mapungubwe National Park. (Photo: Gallo Images / Go! / Villiers Steyn)

By Tony Carnie | 02 Apr 2023

Is it because the Vhembe bioregional plan has been squashed – or held up deliberately – to smooth the passage of the controversial Chinese-led plan to develop a massive new steel plant and special economic zone in the heart of Vhembe district?
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South Africa has an abundance of beautiful places, each judged subjectively through the eyes of the beholders.

But who would argue that the far northern tip of the country is one of the most spectacular and beautiful spaces nationwide?

This is the Vhembe district, that largely open, wild landscape immediately south of the Limpopo River. A place of bright orange sunsets in the heart of baobab country, balancing rocks, abandoned stone citadels and a wealth of plants and animals. Cheetahs, elephants, pangolins and many smaller creatures or vegetation types are found nowhere else in the world.

Right at the top of the district, where our national border meets Zimbabwe and Botswana, lies the Mapungubwe National Park and World Heritage Site. The park takes its name from an ancient kingdom established here in about 900 AD. Later, it became one of the most powerful inland trading settlements in Africa, until its demise in the 13th century.


Mapungubwe National Park, on the South African border with Zimbabwe and Botswana. (Photo: Gallo Images / Media 24)

Vhembe’s eastern corner also incorporates the top section of the famous Kruger National Park. Further south, the landscape is dominated by the heights of the Soutpansberg mountains which includes the sacred waters of Lake Fundudzi, reputed to be protected by a python god.

So, not really any surprise that the unique 3,010,100-hectare surface area of the Vhembe district was recognised as a Unesco biosphere reserve 14 years ago. The Vhembe Biosphere Reserve is part of the World Network of Biosphere Reserves that includes 738 sites in 134 countries. The broad aim of biosphere reserves is to “foster the harmonious integration of people and nature for sustainable development”.

• What unique reasons could there be for delaying the gazetting of the Vhembe plan, when Ledet confirmed that it had received no written objections to the draft version published in 2019?

What is a surprise, however, is why the Limpopo government has buried one of its own biodiversity protection planning tools in a dark cupboard for the past three-and-a-half years.

Limpopo has five districts – Waterberg, Mopani, Capricorn, Sekhukhune and Vhembe. Over recent years, environmental and heritage experts have developed planning tools for all five to safeguard the most sensitive areas from the worst excesses of development – outside formally protected areas such as Kruger and Mapungubwe.

Known as “bioregional plans”, they incorporate a detailed assessment of an area’s biological status and are used in the environmental impact assessment process and by spatial and land-use planners to inform land-use decisions at municipal level.


The Mapungubwe Koppie in the Mapungubwe National Par. (Photo: Gallo Images / Media 24)

The plans are also used by the Limpopo Department of Economic Development, Environment and Tourism (Ledet) to inform development and land-use planning decisions.

All of the Limpopo bioregional plans have been approved and gazetted… except for the Vhembe district.

Why would that be?

Is it because the Vhembe bioregional plan has been squashed – or held up deliberately – to smooth the passage of the controversial Chinese-led plan to develop a massive new steel plant and special economic zone in the heart of Vhembe district?

Significantly, Limpopo’s environmental affairs division falls under the wing of a larger department responsible for economic development, pushing strongly for the new special economic zone.

Our Burning Planet sent several questions to Ledet spokesperson Zaid Kalla to find out why there is such a long hold-up in approving the Vhembe bioregional plan.

We also asked him to comment on allegations by local stakeholders that the plan was stalled due to direct political interference from senior Ledet/Limpopo government officials who fear that the Vhembe bioregional plan is in direct conflict with the proposed Musina Makhado Special Economic Zone (MMSEZ).

Dodging the direct question about political interference, Kalla insisted that the bioregional plan had not been “abandoned at all” and was still being used in “its current status” to inform land-use planning, environmental assessment and authorisations.

Kalla suggested that the Vhembe plan had simply been delayed because the “process (of) gazetting (is) still to be done by the department”.

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  1. Draft bioregional plans for all five districts of Limpopo have been published. The plans forWaterberg, Mopane, Capricorn and Sekhukune have all been approved and gazetted - but the planfor Vhembe has not been gazetted. Is this correct?.
  
  Response: Yes
  
  2. As noted above, the draft Vhembe Bioregional Plan was published in the provincial gazette inAugust 2019 giving a 30-day period for public comment. Three and a half years later, however, theVhembe plan remains unpublished. Can LEDET kindly elaborate on the reasons for this long delay,and any unique factors that distinguish the Vhembe plant from the other four district plans thatwere approved and gazetted?
  
  Response: All five bioregional plans in Limpopo were developed as provided for in the Biodiversity Act,so they can be used to facilitate biodiversity conservation in priority areas outside the protected areasnetwork.
  
  3. If any formal objections/concerns were raised by stakeholders in relation to the Vhembe planduring the 30-day comment period, what was the nature of these objections/concerns and whichspecific bodies/interest groups raised them?
  
  Response: No objections were raised by stakeholders. Only enquiries regarding the purpose ofpublishing the plan and that was dealt with directly with the concerned stakeholder.
  
  4. Some stakeholders have drawn the conclusion that the Vhembe bioregional plan has beendeliberately squashed/suppressed due to direct political interference from senior LEDET/Limpopogovernment officials because of perceptions that the Vhembe bioregional plan is in direct conflictwith LEDA's proposed Musina Makhado Special Economic Zone (MMSEZ). What is LEDET'scomment/response to this allegation?
  
  Response: The Vhembe Bioregional Plan at its current status is still used to inform land-use planning,environmental assessment and authorisations and natural resource management by a range of sectorsincluding LEDET whose decisions impact on biodiversity. The bioregional plan does not replace theneed for site assessments, particularly for Environmental Impact Assessment.
  
  5. Is the draft Vhembe bioregional plan still under discussion or has it been abandoned entirely?
  
  Response: It is not abandoned at all, as indicated above, it is one of the planning tools used in theprovince to inform decision making.
  
  6. If the former, at what point have these discussions reached? Can LEDET give an indication of whenit may be gazetted by the MEC? And should it be published, what are the most significantamendments (if any)?
  
  Response: No amendments the process the gazetting still to be done by the department.
  
  7. If the latter, who gave instructions for the Vhembe plan to be discontinued - and what were thereasons for such decision?
  
  Response: None

But his responses on behalf of Ledet seem wafer-thin, considering that the Sekhukhune and Capricorn plans were gazetted back in March 2020 and the Waterberg and Mopani bioregional plans were also approved and gazetted in January 2019.

What unique reasons could there be for delaying the gazetting of the Vhembe plan, when Ledet confirmed that it had received no written objections to the draft version published in 2019?

Before exploring further answers – in the absence of more cogent explanations from Ledet – a brief explainer about the purpose of bioregional plans may be useful.



The Vhembe Biosphere Reserve, covering more than 3 million hectares of land in Limpopo, is one of more than 700 such reserves globally. (Photo: Vhembe Biosphere Reserve)


The Limpopo River winds through the top section of the Vhembe district. (Photo: Tony Carnie)

In September 2018, the then acting national minister of environmental affairs, Derek Hanekom, wrote a letter to the then Limpopo government MEC in charge of Ledet, Seaparo Sekoati.

Hanekom congratulated Sekoati for his province’s decision to develop a bioregional plan for Vhembe district, which he described as a “significant accomplishment” and “a stepping stone towards the fulfilment of the requirements of our conservation objectives as outlined in the Constitution”: namely to protect and preserve biodiversity for current and future generations.

Noting that the declaration of all new bioregions and bioregional plans require the approval of the national environment minister, Hanekom signalled his official consent to adopting the bioregional plan.

On 30 August, 2019 this draft bioregional plan was published in the Limpopo provincial gazette, giving the public 30 days to comment on the proposal. No formal objections were received. The path was clear.

Remarkably, however, the plan suddenly sank without trace – possibly into the depths of Lake Fundudzi, or was consigned to the back of a dusty cupboard.


A map of the Vhembe-Bioregional-plan, showing the position of the proposed special economic zone and colour-coded biodiversity features of the region. National and provincial parks are in dark green, while critical biodiversity areas and ecological support areas are shown in a lighter shade. Critical biodiversity areas (CBAs) are sites that are deemed essential to meet national biodiversity targets. The majority of these areas in the Vhembe district are classified as CBA 1, which can be considered irreplaceable to meet biodiversity targets. Those areas falling within CBA 2 are considered optimal for achieving biodiversity targets. Ecological Support Areas (ESAs) are areas that are considered important for supporting the ecological functioning of both CBAs and protected areas and for meeting biodiversity targets and connectivity pathways. This category has also been split into ESA1 (areas still in a largely natural state) while ESA2 areas are no longer intact but potentially retain significant importance for ecological processes and landscape connectivity.

‘Conflict’ with coal

Sadly, there is no mystery about the reasons for this, suggests Lauren Liebenberg, founder of the Living Limpopo group which has been campaigning against industrial mega projects such as the Musina-Makhado SEZ and uncontrolled coal mining in Limpopo.

Read more in Daily Maverick: Musina-Makhado Special Economic Zone: The desperate battle to defuse Limpopo’s climate bomb

“The only conclusion that can be reached for the delay in approving the bioregional plan is that Ledet is aware that it is in conflict with the MMSEZ project. The Chinese-controlled special economic zone – as well as many of the proposed coal mining projects in the region – fall within areas that are designated as critical biodiversity areas or ecological support areas.

“There are very, very few places left in the world that are still in a natural state,” says Liebenberg. “Vhembe is one of those special places that have so much potential for visionary plans to be put in place now to protect biodiversity for future generations – before it is too late.” DM/OBP

There are people who are willing to "sell" their country for some kind of economical interest against something which is our heritage and has been there for millions of years and will still be there for all the years to come, if left alone

UNDP moves to scrap support for ‘risky’ R165bn Limpopo heavy industry zone


Illustrative image: The United Nations Development Programme signed a Memorandum of Understanding with South African officials in March 2022 to support the Musina-Makhado Special Economic Zone in Limpopo. A UNDP watchdog has now advised the body to withdraw its backing for the heavy industry plan. (Photos: Supplied and UNDP/MMSEZ press announcement)

By Tony Carnie | 25 Feb 2024

A United Nations internal watchdog unit has advised its biggest development aid agency to scrap an agreement backing the development of a R165-billion heavy industry zone in Limpopo. Citing the risk of significant reputational harm to the United Nations Development Programme (UNDP), the agency’s New York-based Social and Environmental Compliance Unit (SECU) has recommended the immediate cancellation of an agreement signed two years ago to support the controversial Musina-Makhado Special Economic Zone (MMSEZ).
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The project, driven by the state-owned Limpopo Economic Development Agency (LEDA), was initially touted as a R165-billion scheme supported by a consortium of Chinese investors. It would entail building a major 8,000ha heavy industry hub roughly halfway between the towns of Musina and Makhado next to the coal- and mineral-rich Soutpansberg region.


A map showing the boundaries of the proposed MMSEZ. (Photo: MMSEZ environmental impact report)

It would feature up to 20 new industrial projects clustered together in a single tax- and duty-free zone. This would include a new iron and steel plant, a ferrochrome plant, a chrome plating plant; an agro-chemical and petrochemical manufacturing plant; mineral beneficiation; a new Smart City and a logistics cluster projected to attract foreign direct investment. It would apparently create between 21,000 to 53,000 jobs.

However, the project has drawn strong criticism from several quarters for a variety of reasons – including concerns about massive water demands from heavy industry in a water-scarce region; soaring greenhouse gas emissions; pollution; degradation of eco-tourism in Limpopo; and frustrating the access rights of communities who won a land claim around the project site.

Several civil society groups are also contesting the legality of the project in three separate cases currently before courts in Pretoria and Polokwane.

Nevertheless, in March 2022, the South African office of the UNDP – the UN’s largest development aid agency, with offices in more than 170 countries – lent its official backing to the MMSEZ plan when it signed a non-binding memorandum of agreement (MOU). This promised technical backing and expertise along with other unspecified forms of support to foreign investors.

The wording of the MOU indicated that this was the foundation for a more formal partnership in the future, and internal correspondence suggested that the country office “was also considering how the funding for the action plan would be raised”.

Objections lodged


From left: Dr Ayodele Odusola, the UNDP’s former representative in South Africa, and Lehlogonolo Masoga, MMSEZ chief executive, sign the MOU in March 2022. (Photo: UNDP/MMSEZ press announcement)

The agreement was signed by the UNDP’s South Africa representative Dr Ayodele Odusola, who was re-deployed to the agency’s Harare office four months ago.

Now, following a formal objection lodged more than a year ago by social and environmental groups Living Limpopo and Earthlife Africa, the UNDP’s endorsement is set to be cancelled.

In a 29-page final draft investigation report, which came to light at the weekend, the SECU formally recommended that UNDP pull the plug on supporting such a “high risk” project as no due diligence was conducted, as required by UNDP policy.

“The fact that the signing of the MOU resulted in UNDP being publicly identified as a partner means that the mere existence of the signed MOU had significance for (the Limpopo Economic Development Agency). This in turn exposed UNDP to whatever reputational risks may arise from being associated with a company, whose project (pursuant to the applicable policies) the UNDP considers to be high risk.”

Hailing the SECU decision as a significant victory, Living Limpopo spokesperson Lauren Liebenberg said: “The MMSEZ is an environmental and economic Chernobyl, and we are gratified that our objections to its endorsement by the UNDP in this manner has been upheld. We look forward to entering into a constructive dialogue with the UNDP on the alternative, nature-based economic development plan Vhembe Biosphere Reserve for which Living Limpopo advocates.”

Robert Krause, a researcher at the Centre for Applied Legal Studies, suggested that the Limpopo heavy industry cluster also posed “a grave threat” to communities’ livelihoods and their way of life, water security, biodiversity and the prevention of runaway climate change.

“The UNDP and all decision-makers now have a new opportunity to meaningfully consult communities and other stakeholders on how to chart a people-centred development path that brings much-needed broad-based prosperity while conserving this irreplaceable landscape.”

A spokesperson for the UNDP’s Pretoria office confirmed that the SECU report was received on February 21, stating: “We are reviewing the interim findings; we look forward to the final report and recommendations.

“UNDP’s Social and Environmental Standards (SES) are a mandatory requirement for all parts of the organisation – in all programmes and projects – as part of UNDP’s quality assurance and risk management process. The Social and Environmental Compliance Unit (SECU) was established to ensure accountability to individuals and communities we work with. It is important that their voices are heard, and gives UNDP the opportunity to respond to the issues that they raised.”

Senior MMSEZ officials, however, have not responded to requests for comment sent on Friday morning, February 23.

‘Using’ the UNDP

An artist’s impression of part of the proposed MMSEZ project in Limpopo. (Photo: MMSEZ website)

The SECU report notes that the Limpopo government agency sought a written agreement with UNDP “precisely because it believed that engaging with the [UNDP] would help it deal with the challenges that it faced in its relations with outside stakeholders, who were concerned about the potential adverse social and environmental impacts of the project”.

In other words, the Limpopo agency appeared to be “using” UNDP to help it resolve problems with local stakeholders opposed to the project, by listing the UN aid agency as a strategic partner.

“Given that one of UNDP’s strongest assets is its good name and high reputation, the potential costs of exposing itself to reputational risk without proper due diligence are considerable,” the SECU report warns.

SECU stressed that it had not investigated the merits or specific risks of the MMSEZ project. Instead, the eight-month investigation focused solely on whether its South African office had complied with all the applicable UNDP policies and procedures.

It notes that the UNDP has two distinctly different templates for entering into MOUs – one for the private sector and one for governments/state-owned entities. In the case of MMSEZ, the UN country office erroneously signed a less onerous government template.

“The private sector template has provisions dealing with publicity, the use of the UNDP emblem and reputational risk. Had the country office used the private sector template it would have been prompted to seek representations from [LEDA] to assure itself of certain facts before entering into the MOU.

Carbon emissions

“The potential “vast scale use of coal” was one of the many risks flagged by Living Limpopo and Earthlife Africa, who argued that the MMSEZ project was expected to generate nearly 1 billion tonnes of carbon dioxide equivalent emissions over the lifetime of the project – and would therefore consume between 10% to 24% of the country’s carbon emission budget.

This was disputed by the UNDP’s Odusola, who said in July 2022 that MMSEZ had provided assurances that it had “jettisoned” plans for a coal-fired power plant in favour of a renewable energy project.
The SECU report further notes that project documents make it clear that the Limpopo heavy industry plan would be very water-intensive, mainly drawing from the Limpopo River.

“The complainants are concerned that this water will go to the project at the expense of the resiliency of the Limpopo River basin system and all those who depend on it. In other words, they are worried that the project will take the water that they currently depend on for its own purposes, thereby threatening their ability to access enough water for their farms, households and other needs.”

A further risk factor involved potential human rights violations against the Mulambwane community, who were forcibly evicted from their land during the apartheid era.

“Following the advent of democracy in South Africa, the Mulambwane filed a land claim seeking to regain access to their land. Their claim was successful, and they were authorised to take possession of their land again. However, since their legal victory, they have not been able to reclaim their land. This land has now become part of the land that the state has designated for the MMSEZ, further complicating the resolution of this issue.”

As a result, the compliance unit now recommends that UNDP’s South African office should “withdraw” from the MOU.

It said that if LEDA wished to continue its relationship with the UNDP, the parties would need to prepare a new MOU using the correct private sector template, and the UNDP would also need to complete the necessary due diligence “including the necessary consultations with the appropriate offices in the UNDP hierarchy, before signing a new MOU”. DM

LIMPOPO CHAINSAW MASSACRE

Thirsty, energy-hungry steel ‘monster’ set to destroy thousands of Limpopo protected trees in industrial drive


Opponents of the heavy industry plan fear the development will cause irreversible environmental harm to a large section of the Vhembe biosphere reserve. (Photo: Gallo Images / GO! / James Gifford)

By Tony Carnie - 14 Nov 2024

Tens of thousands of indigenous trees — including baobabs and other specially protected species — are set to be the first casualties of a massive heavy industry development plan in Limpopo. The scheme is driven by the provincial government and Chinese developers, who have touted it as ‘the most competitive energy metallurgy special zone in the world’.
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Permit applications sent to the national Department of Forestry, Fisheries and the Environment (DFFE) show that there are plans to destroy as many as half a million protected indigenous trees in the 12,000 hectare Musina-Makahado Special Economic Zone (MMSEZ) in northern Limpopo. This appears to exclude the further destruction of tens of thousands of other more abundant indigenous trees such as mopanes, bushwillows and clusterleafs.

So far, the department confirmed that it has issued licences for the destruction of 1,000 specially protected trees but forestry officials said they would adopt a “cautious and responsible approach” when considering another application to destroy a further 9,000 protected trees.

But there is also a more alarming application in the wings: to remove or destroy more than 650,000 protected trees that include 10,000 baobabs, 100,000 Shepherd’s trees, 120,000 marulas and 428,058 leadwood trees.

Apart from the significant scale of biodiversity damage from tree felling, the plan to develop a new heavy industry zone in Limpopo has also raised concern about whether there is enough water and electricity available in the region to support a mega-scale scale development centred around steel smelting, coal washing and other metallurgical processes.

Nevertheless, the project has received official backing from President Cyril Ramaphosa, Limpopo provincial Premier Phophi Ramathuba and several China-based steel, coal and metallurgy companies. The investors have been wooed with a range of government incentives that include corporate income tax of 15% instead of 27%, as well as cheap electricity supplies – potentially from the Medupi Power Station.


An artist’s impression of the 8,700-hectare southern section of the proposed steel smelting zone in northern Limpopo. (Image: SA Energy Metallurgical Base Limited)

The first destruction licence allows the MMSEZ to chop down 1,000 trees in the northern (Antonvilla) light industrial section of the special economic zone near Beitbridge.

This licence was granted on the condition that the MMSEZ plants 5,000 new seedlings elsewhere to try to mitigate the impact of felling mature trees, some of which may be hundreds of years old.

But the most concerning application – that has now come to light following a Promotion of Access to Information (Paia) application – involves the proposed removal of 658,058 protected trees in the 8,700-hectare heavy industry zone near the town of Makhado.

Records released during the Paia application show that the first application was submitted by senior Limpopo Economic Development Agency (Leda) official Lance Fenn in October 2020. Another MMSEZ official, whose name was redacted for the licence application, submitted a second application, for an identical number of trees (658,058) in the same area, in August 2022.

The applications state that the trees taller than 2m would be cut down using chainsaws, while the stumps would be dug out with mechanical excavators.

According to the DFFE, this application has not been approved, because it failed to meet the conditions required by the National Forests Act, which stipulates that no licences can be issued until the applicant provides proof that they had also complied with other national laws such as the Spatial Planning and Land Use Management Act and Water-Use licence approvals.

One mystifying aspect that has not been clarified is how Leda came up with the figure of over 650,000 protected trees, as previous surveys by environmental consultants Digby Wells and The Biodiversity Company estimated that there were about 109,000 protected trees within the proposed MMSEZ project area.


Limpopo Economic Development Agency CEO Ben Mphahlele (centre) flanked by the Department of Trade and Industry deputy director-general for SEZs, Sipho Zikode, and the vice-president of the China Huadian HongKong Company, Li Lingwei, signing a memorandum of agreement in Beijing in 2018. (Photo: dti)

The tree destruction permit applications came to light after Durban-based AllRise Attorneys were compelled to launch an application in terms of Paia to the DFFE to access this information.

Acting on behalf of several parties strongly opposed to any development that could jeopardise biodiversity in the Unesco-designated Vhembe Biosphere Reserve in northern Limpopo, attorney Kirsten Youens sent a letter to the department on August 13, requesting copies of any tree removal permits in the MMSEZ area.

The applicants included the Vhembe Biosphere Reserve non-profit organisation, Living Limpopo, the Herd Reserve, the Centre for Applied Legal Studies at Wits University and several landowners in the vicinity of the MMSEZ.

Irreversible harm
“What is clear is that granting the licences will cause significant and irreversible environmental harm and loss of biodiversity in the area and is in conflict with the desired state of the region. Our clients are, therefore, strongly opposed to the applications,” she wrote.


A protected baobab tree in northern Limpopo. (Photo: Cameron Spencer / Getty Images)

Youens later received a letter from a senior official in the DFFE legal support division advising that she would have to lodge a Paia application.

Given the top-level political support for the project, it also remains unclear how the DFFE will respond to the application to destroy vast chunks of protected trees in the southern zone, but opponents of the MMSEZ plan fear that the development will trigger a broader domino effect of environmental degradation in the region.

One of the concerns by environmental groups and adjacent landowners is that the development will trigger a massive expansion of coalfields in the surrounding region, leading to the clearance of other large areas of indigenous bushveld and riverine vegetation, the pollution of water and regional water shortages.

A further concern is that Limpopo Department of Economic Development, Environment and Tourism (Ledet) is acting as both developer and referee in the environmental approvals process.

During the initial EIA process, MMSEZ environmental consultant Ronaldo Retief wrote to the then national Department of Environmental Affairs (now DFFE) to clarify whether Ledet should be the competent authority to authorise the project.


A letter from environmental consultant Ronaldo Retief seeking clarity on who should authorise environmental impact studies for the proposed special economic zone. (Image: Supplied)

In September 2018, DEA officials wrote back to Retief to confirm that the application should be submitted to the national department – not the provincial department.

In a subsequent exchange of correspondence, the Centre for Environmental Rights (CER) wrote to then national Environment Minister Barbara Creecy pointing out “the obvious conflict of interest” of Ledet deciding the application when it was also spearheading the MMSEZ project.

The CER noted that a project of this magnitude – which in its first iteration in 2019 involved the construction of a massive 3,300MW coal-fired power station, about 14 heavy metal industries and the potential need to import water from Zimbabwe – could have far-reaching implications for South Africa’s water supply, air pollution, food security and climate change policy and should therefore be considered by her national department.

But Creecy took a different view to some of her senior officials and the CER. In a responding letter in December 2019, she declined to intervene in the EIA process and indicated her view that Ledet was the competent authority to consider the MMSEZ application.

Unsurprisingly perhaps, Ledet gave the project the official thumbs-up in February 2022 while provincial MEC Thabo Mokone soon rejected all appeals against the environmental authorisation.

The development footprint of the 8,700-hectare southern suite was scaled down to around 3,800-hectare and authorisation was only granted for clearance of vegetation, fencing and basic services infrastructure.


A regional map of northern Limpopo showing the location of the two MMSEZ sites and surrounding coal mine concessions. (Image: Toni Oliver / Friedrich Ebert Stiftung)

But these decisions were soon challenged in the high courts in Gauteng and Polokwane by several interest groups for a variety of reasons.

One of their central concerns was that the EIA had been revised to deliberately exclude the cumulative impacts of the main components of the development, a multitude of metal smelting plants, coal washing and the coal-fired power station.

As part of the three court challenges (which are still pending) attorney Youens argued that the MMSEZ had adopted an unacceptable “project-splitting” approach to the authorisation process (by seeking to divide it up into smaller bits and pieces to dilute the true impacts).

In simple terms, the revised EIA application had only considered a limited range of potential impacts and was therefore largely meaningless because it had not assessed the combined impacts of a massive development scheme.


Though there are several elements to the industrial hub, the EIA applications have been split up to show only parts of the overall scheme. (Images: Kinetic scoping report)

MMSEZ chief executive officer Lehlogonolo Masoga later asserted that plans to build a coal-fired power station had been “abandoned” in favour of new solar and hydrogen energy sources.

However, whether the coal-burning plans have in fact been abandoned remains to be seen, as the original project rationale was tied inextricably to the proximity of several new coal mining fields in the adjoining Soutpansberg region.

In an energy feasibility report prepared for the MMSEZ, consultant Cate Rapudi advised against sun power on the basis that a massive 2,000-hectare chunk of land would be needed for a solar plant large enough to power steel smelting and metal processing.


An artist’s impression of a coal-fired power station that was part of the original development plan. (Image: MMSEZ)

Smelter plant

In more recent developments, the Chinese-owned Kinetic Development Group is now applying to Ledet for environmental authorisation for a new ferrochrome and ferroalloys smelter plant with an annual output of up to 1,000,000 tonnes.

Kinetic’s environmental consultants held a “public consultation” meeting on September 3 on a farm outside Makhado, after giving interested parties one day’s notice about the proposed meeting.

At this meeting, Kinetic representatives were quizzed on several issues, including where the water and electricity would come from. According to a table of questions and responses compiled after the meeting, there is still no clarity on where water will come from.


These were some of the original components of the MMSEZ authorisation process. (Image: Supplied)

The table, compiled by Gudani environmental consultants, notes that people at the public meeting were told: “Investigations are being made whether to source water from Zimbabwe, the Limpopo River or to drill boreholes within the SEZ area/farms.”

One of the (unnamed) participants at the public meeting wanted to know more about the proposed 1,000MW solar plant, asking: “Will the solar supply be enough? There are people living in villages as far as Nzhelele without electric power.”

In response, Kinetic representatives stated: “The solar plant is specifically for the proposed projects for industrial purposes as backup power in case of power shortages from Eskom.”

This response suggests that far from generating its own power for the first steel-smelting project, Kinetic is hoping to draw large volumes of electricity from scarce Eskom supplies at a time when the country is emerging from a prolonged load shedding crisis.


Limpopo Premier Phophi Ramathuba (centre) during a visit to the proposed Musina Makhado Special Economic Zone. (Image: MMSEZ Media)

Further evidence that the mega Limpopo metal-processing zone is looking to Eskom for its power is contained in Gudani’s September 2024 scoping report, which states that Eskom had previously indicated that it could supply up to 5MW of electricity for the first year of the MMSEZ operation.

It notes that Eskom’s previous 10-year Transmission Development Plan, also included plans to link up the Medupi Power Station to the Nzhelele sub-station to increase the volume of power available to the new MMSEZ industrial site.

In another significant development, the local MC Mining group recently signed a R1.6-billion agreement with Kinetic, a Hong Kong-listed coal and energy company incorporated in the Cayman Islands tax haven. The deal provides for Kinetic to gain a 51% controlling stake in MC Mining, which has numerous coal mining rights in the region.


Officials from Ledet and the MMSEZ host members of the SA Energy Metallurgical Base and Kinetic at a site visit. (Source: MMSEZ)

Thanks to Kinetic’s recent financial injection into MC Mining, the doors have now been opened for a major expansion of thermal and coking coal on the doorstep of the controversial MMSEZ heavy industrial zone

According to Living Limpopo spokesperson Lauren Liebenberg, this has also increased the likelihood of coal mining groups stripping away further large chunks indigenous trees in Limpopo – a province that features the iconic baobab tree in its provincial coat of arms, its motor vehicle licence plates and the latest Limpopo Investment Conference logo.

Response from the MMSEZ and Ledet

Daily Maverick sent several questions and a request for comment to Ledet and the the MMSEZ on 5 November, but has not received any substantive responses.

Ledet spokesperson Zaid Kalla did not respond to emails or WhatsApp messages.

Chuckling loudly when contacted by phone on 8 November, MMSEZ spokesperson Shavana Mushwana confirmed receipt of our questions sent by email.

However, Mushwana said his current focus was on the Limpopo Investment Conference at the Ranch Resort near Polokwane and he required more time to go through the queries before responding. Also, because of an interdict application in the Limpopo Division of the High Court in Polokwane, he stated that the MMSEZ regarded some of the issues raised to be sub judice.

“So we don’t want to prejudice the legal process,” he said. DM

Full response from the Department of Forestry, Fisheries and the Environment