zo-6-expert-affidavit-of-peter-carrick-b7e481cdac452110.pdf

Expert affidavit by ecological scientist Peter Carrick regarding the proposed expansion of the Tormin Mine on the West Coast of South Africa. Carrick critiques the Terrestrial Ecology Specialist Study (Todd 2018), arguing that the proposed rehabilitation and restoration plans lack specialist knowledge and specific, measurable targets necessary to protect biodiversity and ecological integrity in the Namaqualand Strandveld.

• The proposed expansion of the Tormin Mine by Mineral Sands Resources (Pty) Ltd involves adding 188.7 hectares to mine ten additional beaches north of current operations, conducting inland "strand line" mining on Farm Geelwal Karoo 262, and building additional processing plants and industrial infrastructure.
• Peter Carrick asserts that the Environmental Impact Assessment Report (EIAR) and Environmental Management Programme (EMPr) for the mine expansion contain generalist and often incorrect statements regarding rehabilitation, lacking evidence of specialist management, protocols, or goals for the sea cliffs, foredunes, and Namaqualand Strandveld terrestrial vegetation.
• The Terrestrial Ecology Specialist Study (Todd 2018) is criticized for failing to utilize a significant body of existing research—including over 20 academic theses and scientific papers on mining impacts in the region—and for setting rehabilitation targets for vegetation cover without clear justification or reference sites.
• Carrick identifies a critical failure in the proposed topsoil management; while the plan suggests removing 300mm to 500mm of soil, it fails to recognize that the most vital components—soil nutrients, biota, and the seedbank—are concentrated in the top 50mm, which should be stripped and stored separately from subsoil.
• The affidavit highlights deficiencies in wind erosion management and reseeding strategies, noting that the proposed methods may lead to rehabilitation failure and that the recommendation to use "agricultural methods" for seed collection is impractical due to seed scarcity.
• Concerns are raised regarding the lack of detail for new mining and haul roads, specifically a 15m wide haul road, noting that if stabilization materials like clay, calcrete, hardpan, or saltwater are used, specific rehabilitation will be required which is currently not provided.

APA

Centre for Environmental Rights (n.d.). zo-6-expert-affidavit-of-peter-carrick-b7e481cdac452110.pdf. https://cer.org.za/wp-content/uploads/2021/01/ZO-6-Expert-Affidavit-of-Peter-Carrick.pdf?x21779

Chicago

Centre for Environmental Rights. zo-6-expert-affidavit-of-peter-carrick-b7e481cdac452110.pdf. n.d. https://cer.org.za/wp-content/uploads/2021/01/ZO-6-Expert-Affidavit-of-Peter-Carrick.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=zo-6-expert-affidavit-of-peter-carrick-b7e481cdac452110.pdf |url=https://cer.org.za/wp-content/uploads/2021/01/ZO-6-Expert-Affidavit-of-Peter-Carrick.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndzo6expertaffidavitofpetercarrickb7e481cdac452110pdf, author = {{Centre for Environmental Rights}}, title = {{zo-6-expert-affidavit-of-peter-carrick-b7e481cdac452110.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2021/01/ZO-6-Expert-Affidavit-of-Peter-Carrick.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }