zo-4-expert-affidavit-of-susan-brownlie-2ff2a99cdf3e9ad4.pdf

Expert affidavit by Susan Brownlie regarding the proposed expansion of the Tormin Mine by Mineral Sands Resources (Pty) Ltd. The document argues that the expansion poses significant, potentially irreversible risks to a Critical Biodiversity Area (CBA) and an important ecological corridor, asserting that proposed mitigation measures—specifically rehabilitation and 'search and rescue' of species—are inadequate and scientifically unsupported for the Namaqualand Strandveld vegetation type.

• The proposed section 102 mining extension for the Tormin Mine is primarily located within a Critical Biodiversity Area (CBA) and an important ecological corridor. These areas are designated to maintain ecological processes and fauna dispersal along the coast, and their importance is increased due to significant habitat loss between the Olifants and Sout Rivers.
• The dominant vegetation in the inland mining area, Namaqualand Strandveld, is highly vulnerable to strip mining, which is described as one of the most destructive mining methods due to the total removal of topsoil and vegetation. This vegetation type has declined by more than 20% over the last decade, and its recovery is hindered by an arid, windy climate and nutrient-poor soils.
• The proposed 10m buffer zone between mining activities and coastal dunes is considered insufficient by the Terrestrial Ecology Specialist Study, CapeNature, and the Department of Environmental Affairs: Oceans & Coast. The latter recommended a 20m buffer, but this was not incorporated into the Integrated Environmental Authorisation (IEA).
• The reliance on rehabilitation to mitigate negative impacts is deemed inadequate because Namaqualand Strandveld is extremely slow to rehabilitate and rarely returns to its pre-mining biodiversity. Evidence from a 2018 study on the Namakwa Sands mine showed that while vegetation cover was established, species richness and diversity did not return to reference levels.
• The 'search and rescue' mitigation measure for Species of Conservation Concern (SCC) is criticized by CapeNature and the South African Biodiversity Institute (SANBI). SANBI asserts that ex situ conservation increases extinction risk in the wild and that in situ conservation should be the only recommended option for SCC.
• The document identifies a lack of transparency and detail regarding the mine's rehabilitation plans. The CER reports that Mineral Sands Resources (Pty) Ltd declined to provide the full, final Rehabilitation Plan, and the provided high-level plan lacks detailed action and implementation strategies.
• There is a risk of permanent damage and fragmentation of the CBA if mining continues. The author notes that the site is at a critical point where further expansion could lead to irreversible impacts on the ecological corridor, especially as the company has other prospecting applications in the area.

APA

Centre for Environmental Rights (n.d.). zo-4-expert-affidavit-of-susan-brownlie-2ff2a99cdf3e9ad4.pdf. https://cer.org.za/wp-content/uploads/2021/01/ZO-4-Expert-Affidavit-of-Susan-Brownlie.pdf?x21779

Chicago

Centre for Environmental Rights. zo-4-expert-affidavit-of-susan-brownlie-2ff2a99cdf3e9ad4.pdf. n.d. https://cer.org.za/wp-content/uploads/2021/01/ZO-4-Expert-Affidavit-of-Susan-Brownlie.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=zo-4-expert-affidavit-of-susan-brownlie-2ff2a99cdf3e9ad4.pdf |url=https://cer.org.za/wp-content/uploads/2021/01/ZO-4-Expert-Affidavit-of-Susan-Brownlie.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndzo4expertaffidavitofsusanbrownlie2ff2a99cdf3e9ad4pdf, author = {{Centre for Environmental Rights}}, title = {{zo-4-expert-affidavit-of-susan-brownlie-2ff2a99cdf3e9ad4.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2021/01/ZO-4-Expert-Affidavit-of-Susan-Brownlie.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }