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This document is a supporting expert affidavit and accompanying specialist botanical input statement by Nicholas Helme, a botanical consultant, submitted in a legal matter involving the Centre for Environmental Rights (CER) and several respondents, including the South African Minister of Environment, Forestry and Fisheries. Helme argues that the environmental impact assessments for the MSR Tormin mining extension were flawed due to inadequate botanical surveys, leading to an understatement of the area's botanical sensitivity and a failure to apply the precautionary principle.