Case Decision - 198643

Interim Comment
In order to respond to the submitted letter, SAHRA consulted with two PIA practitioners who conduct work in the area.
As per section 38(3)a and c of the NHRA, the requirements of an HIA include the need to identify heritage resources within a development application area, and to assess any impacts on identified heritage resources within a development area and to assess any potential impacts to unknown heritage resources. In order to assess the impacts on heritage resources, one must first survey an application area to identify heritage resources. In order to assess potential impacts to unknown heritage resources, information regarding the development area must be as up to date as possible.
In order to achieve this, up to date information must be used to conduct these assessments. While surveys have been conducted for the adjacent areas and little to no significant fossils have been identified, these reports provide context for the current application area. However, there are gaps in information regarding the current development application area. It is known that the sensitive Tierberg and Prince Albert Formations are located in the application area, and are overlain by superficial deposits, however, fossils are likely to be present within the sensitive formations. As the application area was last surveyed in 2012, a new palaeontological field-based assessment must be conducted to identify if any sensitive formations are exposed in the application area and to inspect them for potential fossils. SAHRA agrees that excavations into the sensitive formations may reveal potential fossils, however, it is incumbent on the applicant to identify any surface heritage prior to authorisation of a development to provide appropriate mitigation measures and management procedures.
Should the applicant refuse to conduct the required survey, SAHRA will not have sufficient information to provide comments on the application, and therefore will object to the authorisation of the proposed development as the assessment of the impact to palaeontological resources will be incomplete.
SAHRA awaits the requested field-based PIA before further comments are issued.