findings – in particular, using the concept of “complexity” as a polite way of pointing out that some plans were impossible. However, a careful reading of the Matukane report – given below – indicates the very real constraints for water supply for the EMSEZ. The contents and conclusions of the water report were not properly reflected in the consolidated EIA report, a serious flaw. Thus, the many reservations and unfounded and unscientific assumptions pointed out in the Matukane report, are ignored in the main report. The Matukane report states, among others: “…the water demand is substantial if compared to the current water usage in the region. It will become clear that water demand can only be met by current local resources for minimal usage at commencement of the project. As the implementation progresses, the demand for further construction and later process water will grow at an increasing rate, soon to be far beyond what can be met by any possible local supply. Tapping from resources further off, becomes incredibly complex.” (p. 6). And again: “The MM SEZ Southern Development site currently has no direct access to any sustainable water resources sources, apart from groundwater. As discussed, the groundwater potential of the area is very low. Over usage will lead to dewatering, with lowering water tables impacting on the environment, and the authorizations and existing commercial interests of others. (p. 39) This means that construction phase demand for water on the EMSEZ site in Makhado will quickly outstrip locally available groundwater resources. This creates the possibility for local over-use of water, which implies serious risk for other water users in the area. The more unrealistic the timeline for the completion of the Musina and Sand River dams, the bigger these risks will be. The report warns that the EMSEZ (Makhado site) water demand of 80 Mm3 will be reached “within 10 years of commencement”, and that “for any supply for industrial use, water will need to be transferred from where available to the site.” (p. 39). So, if the Musina and Sand dams are not built within a shorter time span than 10 years, there will not be enough water for the EMSEZ to operate. This will tempt the complex to use other water – or it will stop operation.
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