Challenging the Proposed Ferrochrome Smelter in Limpopo
The Herd Reserve, Living Limpopo, and CALS, represented by All Rise Attorneys, have slammed the environmental impact assessment report for a proposed ferrochrome smelter in the controversial Musina-Makhado Special Economic Zone in Limpopo, calling it fundamentally flawed and demanding it be redone.
On 14 August, All Rise Attorneys for Climate and Environmental Justice submitted a 33-page response to the environmental consultant, highlighting serious issues that render the project impossible to recommend for approval. The biggest red flag for stakeholders and authorities is the feasibility study, conducted by a Chinese engineering firm, which openly admits that the project is designed to transfer China's excess steel capacity and reduce China's high energy-consuming pollution to South Africa. In other words, China wants to dump its dirty industry on South Africa.
However, this concern is only one of many if the project were to proceed. The adverse impacts on biodiversity will be substantial. This industrial project, located in the Vhembe Biosphere Reserve, will eliminate 893 hectares of pristine natural bushveld within the 8,000 hectare MMSEZ, and will require the destruction of centuries old baobab trees and habitat for numerous threatened bird and animal species, creating a noxious industrial zone where a functioning ecosystem currently exists.
The climate change impact assessment is particularly concerning. It fails to account for the planned production ramp-up from 125,000 tons of ferrochrome per year to 1 million tons per year and calculates emissions based on the assumption that the plant will maintain its initial, smaller scale indefinitely. This approach understates the actual climate impact of the industrial project by a factor of eight, rendering the assessment totally inadequate for decision-making purposes.
The water resource implications are equally problematic. The region is semi-arid, water-scarce and prone to severe drought conditions, with rainfall having declined by 42% over the past 45 years. Despite these constraints, the project proposes to extract 12.7 million cubic metres of water annually from what is classified as the area's only aquifer requiring the highest level of protection. This raises serious questions about water security in an already water-stressed region.
The air quality assessment exposes a significant omission. The EIA fails to address hexavalent chromium, a known carcinogenic compound and a toxic pollutant emitted by ferrochrome smelters. It also fails to consider the human health impacts of the smelter on the high-density residential development planned for the MMSEZ Township.
The power supply provisions are similarly inadequate. And confusing. Seemingly, the smelter requires 80 MW of electricity to operate, while Eskom can provide only 5 MW - a 94% shortfall. Operating an industrial smelter with only 6% of its required power supply is not technically feasible and thus raises the question as to how the deficit will be met, and what additional environmental impacts will arise.
Local communities face disproportionate impacts. The vulnerable Mulambwane Community and Mopane villagers would lose access to their water supply while receiving minimal employment benefits - the company plans to employ only 235 people at the ferrochrome plant. Additionally, 40% of executive positions would be filled by Chinese workers.
There are also flaws in the EIA process itself as a result of the gross deficiency in the public consultation process. At least 250 registered interested and affected parties did not receive notification when the environmental report was released for public comment. When All Rise raised concerns about this oversight, the environmental consultant, Gudani Consulting, declined responsibility for the notification failures.
“Our submission exposes deep technical and legal flaws in the draft Environmental Impact Assessment Report. From climate impacts and the risk of cancer-causing air pollution, to severe threats to the sole aquifer, impossible energy demands, threats to biodiversity in the Vhembe Biosphere Reserve and irreversible loss of arable land - the report fails communities and nature on every front.” Kirsten Youens of All Rise Attorneys for Environmental and Climate Justice
“Even the dEIAR itself admits the gravity of the project’s impacts: severe water stress and pollution, air quality and health threats, irreversible biodiversity loss, and high greenhouse gas emissions, with almost no lasting employment to offer—just 241 direct jobs. The only real beneficiaries are the Chinese corporate interests, while South Africans are left with the fiscal costs, the pollution, and the irrevocable loss of nature, of la mupo.” Lauren Liebenberg, Living Limpopo
Kinetic Resources’ proposed ferrochrome smelter reflects broader concerns regarding the Musina-Makhado Special Economic Zone and its industrial projects that promise development and high-paid manufacturing sector employment opportunities, but instead deliver environmental degradation, resource extraction and exacerbated poverty and inequality.
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