Interim Comment
The South African Heritage Resources Agency (SAHRA) Archaeology, Palaeontology and Meteorites (APM) Unit will provide further comments once the EIA report is submitted to the case in the EIA public review period. However, the heritage specialist must assess the following to include in the amended HIA report:
It is noted that the HIA report mentions that the proposed mine plans were not provided to the specialists.
Therefore the mine plans must be provided to the heritage specialists and the HIA must clarify whether the proposed mine will impact the identified heritage resources, and provide clear and concise mitigation measures relevant to the potential impacts the mines from the mine as required by section 38(3)b and 38(3)c of the NHRA.
Furthermore, the coal mine will impact very highly sensitive palaeontologically significant rock strata between the coal seams and as such, impacts on palaeontological heritage resources in the proposed area must be assessed in a field-based Palaeontological Impact Assessment (PIA) by a suitably qualified palaeontologist.
A .kml file of the proposed mine right location must be uploaded to the cases palaeo-sensitivity map on SAHRIS.
SAHRA will comment further once a PIA report and an amended HIA report is submitted to the case in the EIA phase of the EA application.