Interim CommentSAHRA is unable to provide a Final Comment on this stage as more information is required. As such, SAHRA requests that a full heritage impact assessment be completed that assesses the impact of the proposed development on all heritage resources including, but not limited to, archaeological heritage, palaeontological heritage, rock art, any significant structures and intangible heritage. This assessment must not only assess impacts in terms of the development footprint, but must also assess broader, indirect impacts to heritage that may result from the proposed development.
The Archaeological Impact Assessment component must identify the archaeological sites to be impacted and assess their significance through a field survey of the 5 site alternatives. It should also make recommendations (as indicated in section 38 of the NHRA) about the process to be followed and regarding which alternative is the most appropriate in terms of heritage. For example, there may need to be a mitigation phase (Phase 2) where the specialist will collect or excavate material and date the site. At the end of the process the heritage authority may give permission for destruction of the sites.
A Palaeontological Field assessment study must be undertaken to assess whether or not the development will impact upon significant palaeontological resources, and to determine if the significant Vruheid Formation outcrops in any of the proposed alternatives. Appropriate mitigation recommendations must be provided as necessary.
Any other heritage resources that may be impacted such as built structures, sites of cultural significance associated with oral histories, burial grounds and graves, graves of victims of conflict, and cultural landscapes or viewscapes must also be assessed.
This assessment must satisfy SAHRA's minimum requirements for impact assessments and must comply with the requirements in Section 38(3) of the NHRA and as such, this assessment must provide recommendations regarding the mitigation of any identified direct and indirect impacts to heritage resources.
SAHRA looks forward to receiving this assessment before commenting further on this proposed development.
CaseReference
Applicable legislation
38(8)
Decision Date
Committee
Decision Status
Case Decision
Case 4225_0.pdf (136.15 KB)