annexures-3bdbf4a4425f6eb6.pdf

The document details the process and disputes surrounding the extension of the Tormin Mineral Sands Mine. It includes a Background Information Document and an Executive Summary of an Environmental Impact Assessment (EIA) prepared by SRK Consulting for Mineral Sands Resources (Pty) Ltd (MSR), outlining plans to mine ten beaches and an inland strandline. It also contains a detailed appeal by the Centre for Environmental Rights (CER), which argues that the extension is an unlawful circumvention of mining right applications, fails to adequately protect Critical Biodiversity Areas (CBAs), and relies on unproven rehabilitation success. Additionally, the CER's correspondence alleges multiple environmental violations by MSR, including unauthorised road construction and sea dumping, and requests the cancellation of the mine's existing rights.

• Mineral Sands Resources (Pty) Ltd (MSR) proposed to extend the Tormin Mine by mining ten beaches totaling 28.7 ha (later cited as 43.7 ha including road widening) and a 75 ha inland strandline on farm Geelwal Karoo 262.
• The proposed extension includes the construction of a Mineral Separation Plant (MSP), a Tailings Disposal Plant (TSP), and a 22 kV powerline from the Sere wind energy facility.
• The EIA identifies that the majority of the application area falls within Critical Biodiversity Areas (CBAs), which are intended to maintain ecological processes and fauna movement along the coast.
• The Centre for Environmental Rights (CER) argues that MSR's use of Section 102 of the MPRDA to expand the mine is an unlawful attempt to bypass the standard application process for new prospecting and mining rights.
• The CER contends that the EIA's reliance on rehabilitation to mitigate impacts in the Namaqualand Strandveld is inappropriate because such vegetation is extremely difficult to rehabilitate and may never be fully restored.
• The CER alleges that MSR has committed several environmental violations, including moving primary beach concentrators without authorisation, causing sea cliff collapse, and dumping tailings into the sea without a permit.
• The CER claims that the financial provision for rehabilitation is insufficient, as it only covers three years of maintenance after closure, despite evidence that impacts persist for decades.
• The EIA concludes that while the project will cause unavoidable adverse environmental impacts, these can be managed to tolerable levels through mitigation and will provide socio-economic benefits.

APA

Centre for Environmental Rights (n.d.). annexures-3bdbf4a4425f6eb6.pdf. https://cer.org.za/wp-content/uploads/2020/10/Annexures.pdf?x21779

Chicago

Centre for Environmental Rights. annexures-3bdbf4a4425f6eb6.pdf. n.d. https://cer.org.za/wp-content/uploads/2020/10/Annexures.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=annexures-3bdbf4a4425f6eb6.pdf |url=https://cer.org.za/wp-content/uploads/2020/10/Annexures.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrightsndannexures3bdbf4a4425f6eb6pdf, author = {{Centre for Environmental Rights}}, title = {{annexures-3bdbf4a4425f6eb6.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2020/10/Annexures.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }