Case Decision - 196346

The South African Heritage Resources Agency (SAHRA) would like to thank you for submitting the Draft Environmental Impact Assessment Report for the Proposed Gas to Power Powership Project at the Port of Saldanha Bay, Saldanha Local Municipality, Western Cape, South Africa.
The project entails the generation of electricity from floating mobile powerships moored in the Port of Saldanha including two ships berthing during the project lifespan namely a Floating Storage Regasification Unit (FSRU), and one Powership. A subsea gas pipeline will connect the FSRU to the powership and a transmission line from the powership will feed the substation and national grid.
Although most of the proposed project is land based, the Maritime and Underwater Cultural Heritage (MUCH) unit is required to comment on the proposed subsea gas pipeline. The preferred route of the pipeline is likely to be perpendicular to the coast and run adjacent to the existing gas pipeline parallel to the Iron Ore jetty and will be approx. 3.5km in length. The pipeline will be brought to site in sections and assembled ready for installation, it will then be pulled into the sea.
SAHRA commented on the Draft Scoping Report (DSR) in November 2020 where it was noted that although a Heritage Impact Assessment (HIA) had been undertaken to assess any possible impacts on terrestrial heritage, no work was undertaken to assess any impacts on maritime heritage. Despite this, the MUCH unit at SAHRA considered the possibility of any impact on maritime heritage resources to be low due to the extensive development of the area in previous years and so it was recommended that “……the DSR still needs to refer to the possibility of impacts and a plan for surveying the pipe laydown area must be incorporated. During the installation of the pipeline the area must be surveyed for heritage remains prior to the laying of the pipeline.”  SAHRA also advised that “…there is still a chance that historic remains could be uncovered during the works. In this case all works must cease and SAHRA must be notified immediately to provide further advice.”
SAHRA is disappointed to note that the DEIA makes no reference to maritime heritage despite part of the project being below the high-water mark. SAHRA’s comments which were provided for the DSR phase of the project have not been considered for inclusion in the DEIA.
While the possibility of encountering maritime heritage is considered to be low, it must be referenced in the EIA so that should heritage resources be encountered during the proposed work, then the correct protocol will be followed.
SAHRA insists that a paragraph must be inserted under section 8.3.12 (Heritage, Archaeology and Palaeontology) to note the need for input on mitigation of impacts to maritime and underwater cultural heritage resources should they be discovered during the pipeline laydown area survey. Section 4.2.1 must also refer to Maritime heritage to show that its presence has been considered.