Comments were submitted by environmental lawyers Cullinan and Associates to Nsovo Environmental Consulting on behalf of the landowners and entities which will be negatively affected by the proposed 131 km power line and substation works in Limpopo Province, South Africa.
“The Limpopo Province is characterised by exceptional biodiversity, offering both opportunities and constraints to development. Being so rich in natural resources – particularly in mineral deposits, agricultural potential, and eco-tourism assets – the province is well-positioned as a key contributor to South Africa’s economy. At the same time, these environmental assets are of national and global significance and therefore require careful management to ensure that development is sustainable and occurs within the ecological limits of the region.
Limpopo’s environmental landscape includes world-renowned conservation areas such as the Kruger National Park, numerous provincial and private nature reserves, two World Heritage Sites, two Ramsar wetlands, three Biosphere Reserves, two Transfrontier Conservation Areas, and several Important Bird Areas and Centres of Floristic Endemism. Collectively, these features form a network of ecosystems that underpin biodiversity, eco-tourism, and community livelihoods, and which contribute significantly to the province’s identity and sustainable development prospects.
Within this context, Foskor (Pty) Ltd operates as a major industrial actor in the province. Foskor is a South African company based in Phalaborwa, specialising in the extraction of phosphate rock, foskorite, and pyroxenite. The extracted phosphate rock is transported daily by rail to Foskor’s acid division in Richards Bay, KwaZulu-Natal, using a dedicated megaRAIL service for the production of phosphoric acid and fertiliser products. These products are primarily exported to international markets, with a smaller portion sold domestically. The proposed Merensky-Foskor 130 km powerline upgrade project has been presented as necessary to sustain and expand Foskor’s industrial operations.
The eco-tourism and conservation-based industries, which are prominent in this province, depend entirely on environments that are natural and that have been altered in only the most minimal way by human structures and activities. In this setting – where biodiversity conservation and sustainable land use are of central importance – any proposed infrastructure must be rigorously assessed to ensure that it does not erode the province’s ecological resilience, scenic integrity or long-term economic sustainability.
Amongst other, the 2025 Draft EIR has accordingly failed to give due consideration to the significance of our clients’ properties as an extension of the protected area complex surrounding the Kruger National Park, and the pristine status of the bushveld environment that will be negatively affected by the proposed powerline project. The consequence of this is that the 2025 Draft EIR has failed to identify and/or understated potentially significant impacts which the proposed powerline project will have for conservation efforts and related eco-tourism initiatives in the area. This failure to conduct a comprehensive, contextual assessment of the impacts on the receiving environment, before the environmental authorisation is granted, leaves significant gaps in understanding the full environmental consequences of the proposed project. This means that the 2025 Draft EIR will not enable a comprehensive consideration of all relevant factors by the competent authority to inform a rational and defensible decision. “
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