Case Decision - 197876

The South African Heritage Resources Agency would like to thank you for submitting the Draft Basic Assessment Report for the for the proposed prospecting in Sea Concession area 14c by Trans-Atlantic Diamonds (Pty) Ltd, West Coast, South Africa.  
In terms of the National Heritage Resources Act, No 25 of 1999 (NHRA), Sections 2 and 35 stipulate that any wreck, being any vessel or aircraft or any part thereof older than 60 years old lying in South Africa's territorial waters or maritime cultural zone is protected and falls under the jurisdiction of SAHRA's Maritime and Underwater Cultural Heritage Unit. These heritage sites or objects may not be disturbed without a permit from the relevant heritage resources authority. 
The prospecting activities described in the report are a geophysical/acoustic survey, Van Veen grab sampling, core sampling and drilling. The geophysical survey is non-invasive and it is proposed that both a multibeam echosounder and sub-bottom profiler will be used. The grab sampling will take between 20-50 samples and will disturb a total surface area of approx. 5m² and a total volume of 1.5 cubic metres (m³). Core samples will be collected at 100-200 sites, it is invasive and will disturb a total surface area of approx. 1.57m and collect a total volume of 4.71m³. The most invasive sampling period will come during the drilling stage. Target areas will be sampled using a drill with a surface area of 5m² and will be done in three steps: (1) An initial 150 samples will be collected and analysed. (2) An additional 150 samples will be collected during follow-up sampling. Should these follow-up samples indicate that there could be a potential resource, only then will step 3 (resource development phase) commence. (3) An additional 60 samples will be collected in a resource area of 500 m x 300 m. Approximately 20 resource development areas will be required. This equates to 1 200 samples. In total, 1 500 samples will be collected and will cover a surface area of 7500m². 
A maritime heritage study has already been undertaken as part of the application process and is included in the DBAR. The specialist study was informed by desktop research and has identified that the potential for disturbing maritime cultural heritage is low. However, records state that there is DEFINITELY one modern wreck within the Sea Concession, the fishing vessel Oceana Sapphire which foundered in 2002. It must be noted that although the wreck of Oceana Sapphire is currently not old enough to be protected by the NHRA, it should still be reported to the authorities if it is discovered as the information can be added to the national shipwreck database. There are five modern wrecks that are POSSIBLY in Sea Concession 14C as they were reported as being lost near the concession. This information regarding the location of the above wrecks would be able to be verified with geophysical data. There are a further 38 wrecks lost in the general area of the concession but whose locations are not known. 
The heritage study has made recommendations and mitigation measures that should be adhered to during the project, these are:

Areas where shipwreck sites are identified during the geophysical surveys must be excluded prior to undertaking sampling activities.
The contractor must be notified that archaeological sites could be exposed during sampling activities, as well as the procedure to follow should archaeological material be encountered during sampling.
Any core sample sections which contain alluvial material, particularly where organic remains are present, are retained and are subject to paleo-environmental assessment.
Any fossils found during the processing of cores must have the details of context recorded, must be kept for identification by an appropriate specialist and, if significant, be deposited in an appropriate institution.
If shipwreck material is encountered during the course of sampling in any of the concession areas, the following mitigation measure should be applied:

Cease work in the directly affected area to avoid damage to the wreck until the South African Heritage Resources Agency (SAHRA) has been notified and the contractor has complied with any additional mitigation as specified by SAHRA; and
Where possible, take photographs of them, noting the date, time, location and types of artefacts found. Under no circumstances may any artefacts be removed, destroyed or interfered on the site, unless under permit from SAHRA.

 
The study has also recommended that the onboard Trans-Atlantic representative must undergo a short induction on archaeological site and artefact recognition, as well as the procedure to follow should archaeological material be encountered during sampling. 
SAHRA supports the recommendations and proposed mitigation measures outlined in the heritage study and included in Section 8.9.3 of the DBAR. 
It has been noted in the Glossary on page viii that SAHRA is called the South African Heritage Resource Association when it should in fact read South African Heritage Resources Agency, it also needs to be corrected on pages xiv, 114 and 128. Please amend these errors in this document and in all future documents. 
While there is only one known shipwreck site and five furthers sites possibly within the proposed prospecting areas there is always the potential for unknown wrecks or shipwreck material to be uncovered during the works. Should anything of archaeological or paleontological significance be exposed during the proposed project, work must cease immediately and SAHRA must be informed of its discovery without delay. In this event, work may not commence until feedback has been received from SAHRA. 
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.