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
https://www.youtube.com/watch?v=REeWvTRUpMk