Interim CommentThe SAHRA Archaeology, Palaeontology and Meteorites (APM) Unit notes the submission of the HIA report along with the draft EIA report however, the SAHRA cannot accept the HIA report as it is. The HIA must be amended to contain cannot provide comment on this development without the following additional information added to the heritage assessment:
Detailed photographs and discription (ie size extent and type of heritage) of each heritage site located within the development footprint must be submitted.
An assessment of impacts to each site must be provided as well as impacts to the sense of place of the general area by the proposed development. The impact assessment must include the distance of each site to the proposed development activities.
The proposed development layout plan must be overlain on the google earth map provided showing its relation to the no-go area and the known heritage resource in the no go area as well as recently identified sites that may be in the construction area must be marked on the map.
The SAHRA cannot provide comment on this development without the following additional information:
The HIA must also include a management plan for long term impacts to the open air site and the rock art. The HMP must address management of access due to the increase in foot traffic to the area due to the development.
It is not clear if there is an existing heritage management plan for the Bokone Northern Sotho Open Air Site and the rock art sites. If there is then it should be assessed and the HIA must address the needs and desirability of the development as part of the long term planning that was identified within the HMP and whether this development is for the benefit of the long term conservation of the rock art sites and stone walling.
In addition there must be a visual impact assessment conducted by a suitably qualified professional with background in history, landscape architecture and the regional vernacular architecture to assess visual impacts of the current development to the existing heritage sites, if the development will impact on the sense of place of the heritage sites, and if the types of structures being proposed are sensitive to cultural sense of place of the development.
It should be noted that the NHRA aims to conserve all values of heritage and the HIA should aim to embody this spirit of conservation by the consideration of the greater area and assessing if the types of heritage found in this study, and assessed as being significant within this area, is well conserved in the region.