Case Decision - 197698

The Maritime and Underwater Cultural Heritage (MUCH) unit at the South African Heritage Resources Agency (SAHRA) would like to thank you for submitting the Draft Situation Assessment Report (SAR) for the development of an Estuarine Management Plan (EMP) for the Kowie Estuary, in Port Alfred in the Eastern Cape, South Africa.
Although it is not currently a legislative requirement that SAHRA issues a comment during this process, as set out in the 2021 National Estuarine Management Protocol (NEMP), there are MUCH resources within the Kowie Estuary that SAHRA is mandated to protect.
The Kowie Estuary catchment area covers approximately 75 748 ha, with the main portion of the estuary being located in the town of Port Alfred in the Eastern Cape. Page 31 of the Draft SAR briefly mentions heritage sites within the Kowie Estuary, stating only as examples, an old stone jetty, and old mill, and shipwrecks. Page 32 provides a map indicating the location of one shipwreck and the requirements of the National Heritage Resources Act, No. 25 of 1999 (NHRA) is briefly alluded to on page 76.
The section pertaining to the NHRA on page 76 should be amended to include a sentence that speaks to the following: “If any listed activity is to be undertaken below the high-water mark of the estuary, an application must be lodged with SAHRA, as SAHRA must comment on potential impacts on MUCH resources in line with Section 38(8) of the NHRA.” This is to ensure that the SAR and EMP will speak to the correct processes to be followed when development within the estuary occurs. As no known heritage specialist reports currently exist for the Kowie Estuary, it is paramount to include guidance in the SAR and the EMP as there may be unknown heritage resources that could be impacted.  
The sections that refer to heritage resources on page 31 and 32 are inadequate in addressing heritage that falls within the Kowie Estuary. These sections should be amended to reflect on MUCH and nearby terrestrial heritage resources in more detail. By including more details about heritage in the SAR and EMP, it will ensure that heritage protection and management will consider heritage more strongly, even if many of the heritage resources are not known yet. For example, it can be mentioned that the unnamed shipwreck, which is only indicated by a pin on a map on Page 32, is that of the Buffalo (1889), an iron paddle-driven steam-powered tug. Furthermore, although the remains are not known to be within the Kowie Estuary, there are at least an additional 24 vessels that have wrecked near the mouth of the Kowie river. Mention should be made of this, because of the dynamic nature of the marine environment, there is a chance that these wrecks, and other unknown ones, may lie within the Kowie Estuary today. Shipwrecks older than 60 years are defined as archaeological in Section 2 of the NHRA and SAHRA is the heritage authority responsible for their protection, as well as for the protection of all heritage resources below the high-water mark. There are, however, other aspects of heritage surrounding the Kowie Estuary that might fall within the remit of a provincial or municipal heritage resources authority – such as the old stone mill – and these should also be expanded upon in more detail.
Please 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.