Interim Comment
The SAHRA Archaeology, Palaeontology and Meteorites (APM) Unit requests that a field-based PIA be conducted as part of the EA process on the following grounds:
The development footprint of the current application (as per the description in the BAR) includes the powerline corridors, Main Transmission Substation (MTS), MTS access road to be widened, powerline access roads to be constructed, and a laydown area of 14 ha. This impact footprint is not small as stated by the specialist in the latest letter;
As per the Heritage Screener and HIA submitted, only the adjacent property for the Vetlaagte has been previously surveyed and the survey coverage of the current application area is mostly low, thus the current status of potential surface exposures is uncertain;
The PIA states on page 14 that “based on the nature of the project, surface activities may impact upon the fossil heritage of preserved in the development footprint. The geological structures suggest that the rocks are the correct type and age to contain fossils”.
As such, SAHRA requires a field-based PIA to be conducted as part of the EA process. Further comments will be issued upon receipt of the above requested report. The applicant is advised to extend the BAR process in terms of section 19(1)b of the NEMA EIA Regulations in order to comply with this comment.