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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.

This expert affidavit by Associate Professor Merle Rozanne Sowman supports an application by the Centre for Environmental Rights (CER) to suspend a decision allowing Mineral Sands Resources (Pty) Ltd (MSR) to expand its Tormin Mine operations on the South African West Coast. Professor Sowman argues that the expansion, which includes ten beaches and inland mining on Farm Geelwal Karoo 262, is causing accelerated cliff erosion and marine sediment pollution, while failing to adequately assess cumulative environmental impacts across MSR's broader regional applications.