zo-39-fdf19e7629224b97.pdf

This document is a formal statement from CapeNature, dated 16 October 2018, providing comments on the Draft Environmental Impact Assessment (EIA) Report for the proposed extension of Tormin Mining activities on Farm Geelwal Karoo No 262, Graauw Duinen No 152, and Klipviey Karoo Kop No 153. CapeNature expresses significant concerns regarding the loss of habitat within a Critical Biodiversity Area (CBA), the uncertainty of rehabilitation in the Namaqualand Strandveld, and the inadequacy of proposed biodiversity offsets and mitigation measures.

• The proposed inland mining expansion is located within a Critical Biodiversity Area (CBA) that serves as an important ecological corridor, particularly given the habitat degradation between the Olifants and Sout Rivers. CapeNature disputes the terrestrial specialists' view that habitat loss would only have local impacts, arguing that any loss of intact CBA has a "high negative impact on at least a regional level" because it compromises conservation targets.
• Rehabilitation of the Namaqualand Strandveld is described as difficult and likely to be extremely slow due to regional aridity. CapeNature notes that there is "extremely limited proof of successful rehabilitation" in the region and warns that the site is unlikely to return to an ecologically equivalent habitat, suggesting that impacts should be viewed as long-term or possibly permanent.
• CapeNature asserts that a biodiversity offset is warranted because the residual impact ratings for construction and operational phases on vegetation and species are "medium negative", which triggers offset requirements under provincial and national guidelines. They argue that managing the remainder of Geelwal Karoo 262 for conservation does not constitute an appropriate offset.
• Regarding beach mining on 10 beaches adjacent to Farm Graauw Duinen No 152 and Klipvley Karoo Kop No 153, CapeNature highlights that severe erosion and cliff collapse occurred after Tormin mine began operating. They question the technical feasibility and monitoring of the proposed 10m wide buffer zone, which relies on assumptions about mining depth and bench face angles.
• The document criticizes the EIA for inadequate alternatives regarding location, layout, and footprint size, stating that specialists were only given one site footprint to assess against a limited discussion of the no-go alternative. Furthermore, CapeNature expresses concern that some mitigation measures were excluded from impact ratings simply because the mining company (MSR) would not commit to them.

APA

Centre for Environmental Rights (n.d.). zo-39-fdf19e7629224b97.pdf. https://cer.org.za/wp-content/uploads/2021/03/ZO-39.pdf?x21779

Chicago

Centre for Environmental Rights. zo-39-fdf19e7629224b97.pdf. n.d. https://cer.org.za/wp-content/uploads/2021/03/ZO-39.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=zo-39-fdf19e7629224b97.pdf |url=https://cer.org.za/wp-content/uploads/2021/03/ZO-39.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndzo39fdf19e7629224b97pdf, author = {{Centre for Environmental Rights}}, title = {{zo-39-fdf19e7629224b97.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2021/03/ZO-39.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }