We assist in the protection of wild species and habitats. Our work in this area includes commenting on policy and legislation, objecting to developments that threaten important habitats, calling for better protection and enforcement, securing permits for the conservation of threatened and protected species and advising on related welfare issues.
Specific project experience to date includes assistance in obtaining sanctuary permits for rescued lions; permits for the acquisition of game for conservation purposes; opinions on the legality of elephant sales and hunts in the SADC region; comments on the high level panel review of the policies, legislation and practices on matters of elephant, lion, leopard and rhinoceros management, breeding, hunting, trade and handling; and the expansion of protected areas.
Projects:
The Impact of Coal Mining on Land, Communities, and the Environment
Coal mining consistently forecloses alternative, more sustainable land uses; undermines biodiversity conservation efforts; severely impacts water resources; displaces people from their land; and destroys subsistence-based livelihoods and cultural heritage. It often causes community divisions and erodes the constitutionally protected right—under Section 24 of the Constitution of 1996—to an environment that is not harmful to health or well-being.
Mining Operations
- Mbila Resources (Pty) Ltd
- Holds mining rights for: Msebe Opencast Anthracite Mine and Mbila Underground Mine.
- Located east of Nongoma in the Zululand District Municipality.
- Tendele Coal Mining (Pty) Ltd – Somkhele
- Operating in the Mpukunyoni Traditional Authority area.
- Impacts the iMfolozi and other nearby catchments.
- Located on the eastern boundary of the park and directly north of Imvukuzane’s proposed site.
- Zululand Anthracite Colliery (ZAC)
- Ongoing and future mining northwest and west of Imvukuzane’s proposed area.
- Within iMfolozi catchment and five traditional authorities: Zungu, Matheni, Mlaba, Mandlakazi, and Ximba.
Prospecting Mining Rights/ Mining Right Applications
- Imvukuzane Prospecting Activity in the Fuleni Reserve
- Prospecting right applied for.
- Adjacent to ongoing and future mining operations by Zululand Anthracite Colliery (ZAC).
- Falls within the traditional authority areas of Zungu, Matheni, Mlaba, Mandlakazi, and Ximba.
- Located in the iMfolozi catchment and borders the northern and western edges of Hluhluwe-iMfolozi Park.
- The prospecting right is valid until August 2028.
- Tendele Coal Mining (Pty) Ltd – Somkhele
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- Ongoing and future operations in the Mpukunyoni Traditional Authority area.
- Located within the iMfolozi and adjacent catchments.
- Borders the eastern edge of Hluhluwe-iMfolozi Park and lies directly north of Imvukuzane’s proposed site.
- Yengo Resources (Pty) Ltd
- Prospecting application in Ximba Traditional Authority on the southwestern boundary of Hluhluwe-iMfolozi Park.
Recent application to amend existing right – objections have been formally submitted. - Area was previously prospected by ZAC.
- Raycom Resources (Pty) Ltd
- Prospecting application southwest of the Imvukuzane area and Hluhluwe-iMfolozi Park.
- Ibutho Legacy (Pty) Ltd
- Previously conducted prospecting in the same area now proposed by Imvukuzane.
- MDZ Fleet Solutions
- Prospecting application in the King Cetshwayo District (near Empangeni), close to Thula Thula Game Reserve.
- Nomaphenduka Group
- Application for prospecting rights in the Mpembeni area for titanium, heavy minerals, aluminium, manganese, and iron ore.
- Afri In Transit (AIT) Group
- The latest application covers 7,500 hectares of communal land in the Somkhele area, bordering Hluhluwe-iMfolozi Park.
- Application still under review.
- Saqondisana Investments
- Three prospecting right applications south of Hluhluwe-iMfolozi Game Reserve
- Mikatekoo (Pty) Ltd
- The application covers the town of Melmoth, 30 kilometres south of uLundi within the Uthungulu Magisterial District.
Withdrawn Applications
- Jaments (Pty) Ltd
- Mdletshe and Mpukunyoni Traditional Authorities (eastern boundary of the park).
- Withdrawn after public objections and consultation.
- Tornowize (Emalahleni)
- Application on the southern boundary of Hluhluwe-iMfolozi Park.
- Withdrawn following opposition from traditional leaders and their council.
- Jaments (Pty) Ltd
- Application in the uMkhanyakude District (northwestern side of the park) withdrawn.
The proposed Musina Makhado Special Economic Zone (“MMSEZ”) development is a Chinese-funded “megacity” in Limpopo Province, driven by the Limpopo Provincial government. The entire project spans over 60 km² of land in total.
The MMSEZ has been sanctioned as a “China-Africa capacity cooperation” project under a memorandum of understanding (MOU) signed by President Cyril Ramaphosa and China’s Xi Jinping at the 2018 Forum on China-Africa Cooperation (FOCAC).
The individual industrial projects within the MMSEZ include a 3300 MW coal-fired power station as well as coke, carbon steel, pig iron, ferrochromium, ferromanganese, silicon-manganese and calcium carbide plants.
The MMSEZ project is anticipated to bring severe environmental threats to the Vhembe Biosphere Reserve—a UNESCO-designated conservation area. The project overlaps with protected land, risking ecocide through deforestation, depletion of limited water resources, and increased pollution. These impacts threaten biodiversity, contribute to climate change, and undermine sustainable economic sectors like tourism, reflecting a broader conflict between coal-fuelled industrialisation and environmental preservation.
The scale of the development has the potential to radically alter the environmental, social and economic landscape of the Vhembe Biosphere Reserve region, and the risks demand considered decision-making around environmental authorisation. It will result in a severe setback to efforts to fight the climate crisis and render South Africa in breach of its international obligations.
Project developers:
- Shenzhen Hoimor Resources Holding Co. Ltd. (Hong Kong) [Operator]: South African Energy Metallurgical Base Pty Ltd (South Africa) [subsidiary]
- Musina-Makhado SEZ (SOC) Ltd (South Africa)
Our clients:
- Living Limpopo
- The Herd Reserve
- Centre for Applied Legal Studies (CALS)
Find more information in our Background on MMSEZ, Limpopo.pdf fact sheet.
Comments on EIA for land clearance:
22 October 2020: EIA process Comments
23 March 2022: MMSEZ EIA Appeal.pdf
- Annexure A1 ALL RISE and CALS Appeal to MMSEZ EA.pdf
- Annexure A2 Submissions on the EMSEZ draft EIA 22 Oct 2020 Final.pdf
- Annexure A3 2021 09 15 Letter to EAP MMSEZ.pdf
Review application:
15 December 2022: filed on behalf of CALS, Living Limpopo and the Herd Reserve:
- Notice of Motion and Founding Affidavit
- Rule 16A Notice
- Rule 41A Notice
- Section 20(2) Notice
- Notice of Intention to Oppose – 2nd and 3rd Respondents
4 April 2025: Supplementary Founding Affidavit for the MMSEZ Review Application
Find more details in our MMSEZ Review Application Fact Sheet.
Other Development and Environmental Applications:
- Comments on EIA for ferrochrome smelter:
9 December 2024: 2024 12 9 ALL RISE Comments on Ferrochrome Smelter Scoping Report MMSEZ.pdf
19 May 2025: 2025 5 19 Letter to Minister George re MMSEZ final.pdf
- Objections to Water Use Licence Application: 16 July 2024: Objections
- Objections to township application: 26 July 2024: Objections
Find more details in our Other development and environmental applications fact sheet.
Applications for Destruction of Protected Trees:
On 12 August 2024, All Rise, acting on behalf of the Vhembe Biosphere Reserve, Herd Reserve, Living Limpopo and the Centre for Applied Legal Studies (CALS), JL Du Preez & Sons CC, submitted a PAIA application to the Department of Forestry, Fisheries and the Environment for copies of applications made and/or permits issued to destroy or remove protected trees in the Vhembe area.
The most shocking application submitted was to destroy over 648 000 trees, 10 000 of which are Baobabs on the “south site”.
12 August 2024: Letter to DG Forestry Management .pdf
Find more details on the MMSEZ Applications for the Destruction of Protected Trees fact sheet.
All Rise has been a member of WAPFSA since 2023. The overarching objective of WAPFSA is to facilitate the creation of a strong social movement towards wildlife protection that advocates locally and globally so as to create awareness and to lobby and affect policy and legislative remedies and change relating to:
- The loss, contamination, fragmentation, degradation and climate alteration of suitable habitat for wild animals;
- The captive breeding, keeping, exhibition, management, handling, trading, oppression and trophy hunting of wild animals and their body parts for commercial purposes and associated exploitation.
All Rise is a member of the Global Alliance for the Rights of Nature (GARN) African Hub. GARN is a network of organisations and individuals committed to the universal adoption and implementation of legal systems that recognise, respect, and enforce Rights of Nature.
- DFFE Wildlife Well-Being Forum
All Rise’s application to the Wildlife Well-Being Forum (WWBF) was recommended, without any objections, at the WWBF meeting of 19 February 2025.
We now await the approval of the Director-General (DG) of the Department of Forestry, Fisheries and the Environment (DFFE).
The “Ministerial Wildlife Well‑Being Forum” was established by DFFE in May 2023. It brings together national and provincial governments, state‑owned bodies, NGOs, specialist institutions, professional councils, and associations that focus on wildlife, biodiversity, and animal well‑being.
The objective of the Wildlife Well-Being Forum is to work as a collective towards promoting:
- Conservation through sustainable use of renewable natural resources;
- A responsible, self-regulatory and practical wildlife and hunting industry;
- Creating conditions for, and implementing transformation in the whole sector;
- Sector-related sustainable tourism growth and development.