EXPERT AFFIDAVIT

This document is an expert affidavit submitted by Susan Frances Brownlie, an Environmental Scientist and Environment Assessment Practitioner, in support of a legal matter in the High Court of South Africa. Brownlie confirms her authorship and the findings of a December 2022 report reviewing the Environmental Impact Assessment (EIA) and Environmental Authorisation for the proposed Musina Makhado Special Economic Zone in Limpopo.

• Susan Frances Brownlie provides an expert opinion and findings regarding the Environmental Impact Assessment (EIA) and the Environmental Authorisation granted for land clearance and other activities associated with the proposed Musina Makhado Special Economic Zone Project.
• Brownlie confirms the validity of a report titled "Review of the EIA documentation, the Environmental Authorisation and the Appeal findings: proposed fVusina Alakhado Special Economic Zone, Limpopo", dated December 2022, stating that the methodologies used are credible and robust.
• The deponent, Susan Frances Brownlie, possesses approximately 43 years of experience in environmental assessment and management, holding a Master's Degree in Environmental Studies from the University of Cape Town (1982) and having served as an advisor to the International Union for the Conservation of Nature (IUCN) and the Department of Environmental Affairs.

APA

BROWNLIE, S. F. (2022). EXPERT AFFIDAVIT. Centre for Environmental Rights. https://cer.org.za/wp-content/uploads/2023/01/Susan-Frances-Brownlie-Commissioned-Expert-Affidavit.pdf?x21779

Chicago

BROWNLIE, SUSAN FRANCES. EXPERT AFFIDAVIT. Centre for Environmental Rights, 2022. https://cer.org.za/wp-content/uploads/2023/01/Susan-Frances-Brownlie-Commissioned-Expert-Affidavit.pdf?x21779.

Wikipedia

{{cite press release |last1=BROWNLIE |first1=SUSAN FRANCES |title=EXPERT AFFIDAVIT |publisher=Centre for Environmental Rights |date=2022 |url=https://cer.org.za/wp-content/uploads/2023/01/Susan-Frances-Brownlie-Commissioned-Expert-Affidavit.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{brownlie2022expert, author = {BROWNLIE, SUSAN FRANCES}, title = {{EXPERT AFFIDAVIT}}, publisher = {Centre for Environmental Rights}, year = {2022}, url = {https://cer.org.za/wp-content/uploads/2023/01/Susan-Frances-Brownlie-Commissioned-Expert-Affidavit.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }