Case Decision - 197189

The South African Heritage Resources Agency (SAHRA) would like to thank you for submitting a Draft Scoping Report (DSR) under section 38(8) of the National Heritage Resources Act, No 25 of 1999 (NHRA) for a Diamond Prospecting Right in the Offshore Concession (sea concession 4C and 5C) off the West Coast, South Africa.
The application pertains to prospecting activities for diamonds in four phases. The first phase involves desktop studies, the second phase entails geophysical surveying, the third phase includes invasive exploration sampling, and the fourth phase entails a feasibility study. The desktop phase will involve understanding the proposed diamond deposit character and the geophysical surveying will involve equipment appropriate for the depth and survey method. The invasive sampling phase of the project will include the use of crawlers on board vessel(s) to dredge materials from the seabed and these will be sifted on board the vessel(s).
Although the Namaqua Fossil Forest Marine Protected Area (MPA) is located within sea concession 4C and 5C, the DSR mentions that this area will be excluded from all prospecting activities, including surveying. SAHRA is satisfied with the high-level mitigation measures indicated in Table 20 on page 51 in that those areas where shipwreck sites are known are to be excluded. However, most wreck locations are unknown, and provisions must be made for the potential impact and mitigation measure on these and included in that portion of the table.
The DSR further mentions that an Underwater Heritage Impact Assessment is proposed. A heritage impact assessment (HIA) for sea concession 4C, 5C, and 6C was conducted in 2017. This HIA found that at least five vessels wrecked in sea concession areas 4C, 5C, and 6C and that a further 28 vessels might have wrecked somewhere in the area. As the DSR proposes potential invasive sampling methods which could destroy underwater heritage resources, SAHRA supports that the project should include an Underwater HIA. SAHRA looks forward to seeing the recommended management measures that the Underwater HIA must include, as is alluded to on page 55 of the DSR.
SAHRA has noted inaccurate information in the report which needs updating. On page 44 under the heading ‘Marine Archaeological Sites’ the estimated number of shipwrecks along the South African coastline is listed as 2000 when the number is in fact closer to 2800. In the same paragraph, mention is made of the National Monument’s Council (NMC) as providing protection for wrecks older than 60 years. Please note that NMC ceased to exist in 2000 when the promulgation of the NHRA established SAHRA as the national heritage resources authority. All wrecks and associated artefacts older than 60 years are considered archaeological and are therefore provided protection under section 2 and 35 of the NHRA as opposed to having National Monument Status as indicated in the DSR. These above points must be amended in the final scoping report.
If any wrecks are encountered, the location and associated data used to identify the wreck must be provided to SAHRA. Should any shipwrecks be identified as part of this project then SAHRA must be notified to enable the information to be added to the national shipwreck database. Any new discoveries or updated data is a valuable resource in adding to our knowledge of South Africa’s maritime history.
Please also note that all updates and/or changes to the project, supporting documentation, correspondence, reports, or any other work relating to the project must be uploaded to the case on SAHRIS to provide SAHRA with the opportunity to comment. SAHRA does not accept emailed documents or hard-copy documents received via post.