Case Decision - 198731

Final Comment
The SAHRA Archaeology, Palaeontology, and Meteorites (APM) Unit notes the submission of the draft BAR, and the Heritage reports. SAHRA does not support the following proposed developments:The Schroda Orientation Centre;The Mapungubwe Orientation Centre;The K8 Orientation Centre.The reasons are as follows:

A permanent building constructed on intact deposits is not suitable for long-term conservation and research potential of the site.
The HIA report did not identify and assess additional Orientation Centre footprint locations that will not impact intact archaeological deposits. 
The HIA report does not provide details of the current extent of the open excavation site k8, as well as the proposed height and extent of the new structure. Therefore, the impact area is not known.
There was no discussion regarding the stabilisation project undertaken in 2003 in the HIA (https://sahris.sahra.org.za/sites/default/files/heritagereports/9-2-040-...), nor did it provide an assessment of the recommendations of the stabilisation project report to inform the proposed developments at site K8. 
The Landscape and Visual Impact Assessments do not provide sufficient detail regarding the visual impacts of the Mapungubwe Orientation Centre, on Mapungubwe Hill and K2. The VIA provides one photo of the view of the Mapungubwe Orientation Centre from half-way up Mapungubwe Hill. When on top of the hill, the orientation centre is in line with the site.
The Tourism Study indicated that the needs and desirability of the Orientation Center in the Mapungubwe Valley are based on accessibility and safety concerns and not the enhancement of the heritage and authenticity of the landscape, and the interpretation of the heritage of Mapungubwe.

Based on these reasons, the SAHRA cannot support these Orientation Centre developments at Mapungubwe Hill and Schroda. If the competent authority approves these activities, it must be noted that section 27 permit application of the NHRA is still required prior to the commencement of the development activities. 38(4)a – The SAHRA Archaeology, Palaeontology and Meteorites (APM) Unit has no objections to the construction of the Overnight dormitory facilities on the following conditions:38(4)b – The recommendations provided by the heritage specialists pertaining to the Overnight dormitory facilities are supported and must be adhered to. Additional specific conditions include the following: A suitably qualified archaeologist must be present to monitor all ground clearance activities and foundation excavation activities on site;A section 27 permit application for the construction of the dormitories must be applied for by a suitably qualified archaeologist.The Fossil Chance Finds Procedure must be included in the construction management plan for implementation in the event that any fossils are uncovered during construction.38(4)c(i) – If any evidence of archaeological sites or remains (e.g. remnants of stone-made structures, indigenous ceramics, bones, stone artefacts, ostrich eggshell fragments, charcoal and ash concentrations), fossils or other categories of heritage resources are found during the proposed development, SAHRA APM Unit (Nokukhanya Khumalo/Phillip Hine 021 202 8654) must be alerted as per section 35(3) of the NHRA. Non-compliance with section 35 of the NHRA is an offence in terms of section 51(1)e of the NHRA and item 5 of the Schedule;38(4)c(ii) – If unmarked human burials are uncovered, the SAHRA Burial Grounds and Graves (BGG) Unit (Thingahangwi Tshivhase/Ngqalabutho Madida 012 320 8490), must be alerted immediately as per section 36(6) of the NHRA. Non-compliance with section 36 of the NHRA is an offence in terms of section 51(1)e of the NHRA and item 5 of the Schedule;38(4)d – See section 51(1) of the NHRA regarding offences;38(4)e – The following conditions apply with regard to the appointment of specialists:i) If heritage resources are uncovered during the course of the development, a professional archaeologist or palaeontologist, depending on the nature of the finds, must be contracted as soon as possible to inspect the heritage resource. If the newly discovered heritage resources prove to be of archaeological or palaeontological significance, a Phase 2 rescue operation may be required subject to permits issued by SAHRA;The Final BAR must be submitted to SAHRA for record purposes;The decision regarding the EA Application must be communicated to SAHRA and uploaded to the SAHRIS Case application.