nick-helme-supporting-expert-affidavit-6b249e74aed5fed0.pdf

This document is a supporting expert affidavit and accompanying specialist botanical input statement by Nicholas Helme, a botanical consultant, submitted in a legal matter involving the Centre for Environmental Rights (CER) and several respondents, including the South African Minister of Environment, Forestry and Fisheries. Helme argues that the environmental impact assessments for the MSR Tormin mining extension were flawed due to inadequate botanical surveys, leading to an understatement of the area's botanical sensitivity and a failure to apply the precautionary principle.

• Nicholas Helme asserts that the Terrestrial Ecology Specialist Study (Appendix 11F of the EIAR) understated the botanical sensitivity of the section 102 mining extension area and failed to apply the precautionary principle when knowledge was limited.
• The botanical surveys conducted by the specialist Todd (2018) were constrained by seasonality, as none of the three site visits occurred during the optimum spring flowering season (early August to early September). This omission likely resulted in the failure to record 20% to 40% of the total plant diversity, specifically bulbs and annuals.
• Helme identifies a high probability that the beach mining areas support at least four plant Species of Conservation Concern (SCC): Oncosiphon schlechteri, Helichrysum dunense, Drosanthemum marinum, and Manulea cinerea, based on his own surveys of adjacent properties.
• The 64ha facility footprint and 75ha inland mining area are likely to support between 5 and 10 plant SCC, including Eriospermum arenosum, Leucoptera nodosa, Wahlenbergia asparagoides, Lapeirousia simulans, Muraltia obovata, Helichrysum tricostatum, Babiana teretifolia, Babiana brachystachys, and Ferraria foliosa.
• There are three undescribed plant species known from the region's habitat (Nemesia sp. nov., Gethyllis sp. nov., and Arctotis sp. nov. rubrosabulosa MS), two of which are rare and threatened. Helme suggests the inland development footprints could contain as many as 12 or 13 plant SCC in total.
• Nicholas Helme formally agrees with several grounds of review in the CER's application, specifically those regarding the flawed approach to evaluating terrestrial biodiversity impact significance, the failure to account for the precautionary principle, the failure to consider cumulative impacts on marine and terrestrial ecology, and the failure to consider climate change impacts.

APA

Centre for Environmental Rights (n.d.). nick-helme-supporting-expert-affidavit-6b249e74aed5fed0.pdf. https://cer.org.za/wp-content/uploads/2021/03/Nick-Helme-Supporting-Expert-Affidavit.pdf?x21779

Chicago

Centre for Environmental Rights. nick-helme-supporting-expert-affidavit-6b249e74aed5fed0.pdf. n.d. https://cer.org.za/wp-content/uploads/2021/03/Nick-Helme-Supporting-Expert-Affidavit.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=nick-helme-supporting-expert-affidavit-6b249e74aed5fed0.pdf |url=https://cer.org.za/wp-content/uploads/2021/03/Nick-Helme-Supporting-Expert-Affidavit.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndnickhelmesupportingexpertaffidavit6b249e74aed5fed0pdf, author = {{Centre for Environmental Rights}}, title = {{nick-helme-supporting-expert-affidavit-6b249e74aed5fed0.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2021/03/Nick-Helme-Supporting-Expert-Affidavit.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }