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This expert report, prepared by geologist and hydrogeologist Steven K. Campbell for the Centre for Environmental Rights, critiques the Environmental Impact Assessment (EIA) for Tetra4 (Pty) Ltd’s proposed Cluster 2 gas production expansion near Virginia, Free State Province, South Africa. Campbell argues that the project's geologic and hydrogeologic frameworks are based on insufficient site-specific data, leading to unreliable groundwater flow models and flawed contamination simulations for methane and total dissolved solids (TDS). He concludes that the expansion should not be approved until critical data gaps are filled and a robust monitoring and remediation plan is established.