Applicable legislation
38(8)
Decision Date
Decision Status
Case Decision

The South African Heritage Resources Agency (SAHRA) would like to thank you for submitting the Draft Basic Assessment Report (DBAR) as part of Section 38(8) of the National Heritage Resources Act (no. 25 of 1999) for the project ‘Proposed Refurbishment and Construction of Coastal Infrastructure Within the King Sabata Dalindyebo Local Municipality, Hole in the Wall, Eastern Cape.’
SAHRA is the heritage authority responsible for the identification, protection, and promotion of all heritage resources located below the high-water mark and within the maritime cultural zone of the Republic, as well as those situated in, or associated with, inland lakes, rivers, or other bodies of water. This includes, inter alia, shipwrecks older than 60 years and their associated cargo and debris, heritage resources in the intertidal zone, and intangible heritage associated with water.
The aforementioned project entails the refurbishment and construction of coastal infrastructure near the Hole in the Wall landmark with the key objective being to promote and develop sustainable coastal infrastructure. There are no planned construction activities below the high-water mark. Via a comment sheet during the Background Information Document (BID) phase of the Basic Assessment (BA) process, SAHRA registered as an Interest & Affected Party (IAP) and advised that the Heritage Impact Assessment (HIA) must consider the potential of finding heritage resources in the dunes above the high-water mark as these may be maritime in character. SAHRA now notes that the HIA report that forms part of the DBAR identifies the Hole in the Wall as a living heritage resource. Although no construction activities are planned within 150m of the Hole in the Wall landmark, it remains important to ensure that the intangible heritage aspect of this underwater living heritage resource is safeguarded during the nearby construction activities.
The HIA reports that the Hole in the Wall is protected by the NHRA under section 3.2.1 and under section 6 of the HIA it recommends that a 50m buffer must be maintained around the feature and that the local beliefs relating this feature must be respected. Section 5.2 states that the cultural landscape of the Hole in the Wall has heritage significance and under section 6, on page 24 of the HIA it is recommended that discussions with the local community need to be scheduled as the community has raised concerns about developments compromising the local ‘sense of place’. SAHRA agrees with the HIA report in that the local community’s concerns need to be addressed in a responsible and systematic manner as part of the project’s key objective of developing sustainable coastal infrastructure. The Final Basic Assessment Report must detail the public participation process to show how these concerns with the local community were addressed so that the living heritage associated with Hole in the Wall is safeguarded.
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.