supporting-affidavit-2-merle-sowman-8a4a8a06f57f4be6.pdf

This supporting expert affidavit, submitted by Associate Professor Merle Sowman, argues that the Environmental Impact Assessment (EIA) for the proposed extension of the Tormin Mine by Mineral Sands Resources (Pty) Ltd (MSR) failed to adequately assess cumulative environmental and socio-economic impacts. Sowman contends that assessing applications on an ad hoc basis ignores the broader scale of MSR's regional mining plans and calls for a Strategic Environmental Assessment (SEA) to prevent irreversible damage to critical biodiversity areas and sensitive coastal ecosystems.

• The Environmental Impact Assessment (EIA) for the Tormin Mine extension is considered insufficient because it is a project-level tool that fails to account for cumulative impacts from MSR's existing activities, other prospecting and mining applications in the region, and other regional mining operations such as the Namakwa Sands mine.
• If all of MSR's current applications are approved, the potential impact would cover approximately 63 km of coastline and estuary frontage (52 km of coastal and 11 km of estuary frontage), affecting an area of roughly 11,500 hectares.
• Specialist reports for the Tormin Mine extension generally failed to assess cumulative impacts according to the NEMA definition, though some noted that further expansion would create "additive, spatial and temporal cumulative impacts on the faunal beach communities" and "progressively escalating impact" in inland mining areas.
• The current ad hoc, project-by-project assessment process is described as contrary to EIA Regulations and the 2014 Environmental Impact Assessment and Management Strategy (EIAMS) for South Africa, which suggests that Strategic Environmental Assessments (SEAs) or Environmental Management Frameworks (EMFs) are better suited for cumulative assessments.
• The author argues that a comprehensive Strategic Environmental Assessment (SEA) is critical before further authorizations are granted because the area is a critical biodiversity area, an important ecological corridor, and is located near the Olifants estuary, the third most important estuary in South Africa.
• Failure to conduct a cumulative impact assessment risks irreversible damage to critical biodiversity areas, marine habitats, heritage and palaeontological resources, and may cause socio-economic harms including restricted public coastal access and pressure on scarce water resources.

APA

Centre for Environmental Rights (n.d.). supporting-affidavit-2-merle-sowman-8a4a8a06f57f4be6.pdf. https://cer.org.za/wp-content/uploads/2020/10/Supporting-Affidavit-2-Merle-Sowman.pdf?x21779

Chicago

Centre for Environmental Rights. supporting-affidavit-2-merle-sowman-8a4a8a06f57f4be6.pdf. n.d. https://cer.org.za/wp-content/uploads/2020/10/Supporting-Affidavit-2-Merle-Sowman.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=supporting-affidavit-2-merle-sowman-8a4a8a06f57f4be6.pdf |url=https://cer.org.za/wp-content/uploads/2020/10/Supporting-Affidavit-2-Merle-Sowman.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndsupportingaffidavit2merlesowman8a4a8a06f57f4be6pdf, author = {{Centre for Environmental Rights}}, title = {{supporting-affidavit-2-merle-sowman-8a4a8a06f57f4be6.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2020/10/Supporting-Affidavit-2-Merle-Sowman.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }