Case Decision - 199130

The South African Heritage Resources Agency (SAHRA) would like to thank you for the letter issued in November 2022 in response to SAHRAs comment for the Draft Environmental Impact Assessment Report for the Proposed Gas to Power via Powership Project at the Port of Richards Bay, uMhlathuze, KwaZulu-Natal, South Africa. 
In the comment dated November 2022, SAHRA noted that the sections relating to heritage, namely Sections 7.5.6 and 7.5.10 had been updated from the previous version (April 2021) and had been changed so that they do not adequately address heritage resources. SAHRA requested that the information contained in Section 8.3.14 of the April 2021 FEIA be reinstated to this report to meet requirements and also advised that sections 7.5.6 and 7.5.10 be updated to include the information from the above noted section. It was also noted that the Heritage Impact Assessment (HIA) recommended 2 mitigation measures to be included in the EIA as advised by the specialist (as stated on pages 23 and 31 of the HIA). 
In November 2022 SAHRA received a letter from Triplo4 in response to the above comment where it stated that “heritage impacts, including underwater heritage, were considered and captured in the draft EIA Report, in sections 7.5.6 and 7.5.10. In terms of the Underwater Archaeology, it was determined that there is an extremely low probability of Maritime and Underwater Cultural Heritage resources being found in the Port of Richards Bay. It was further indicated that the specialist recommended the need for input in the EMPr on mitigation of impacts to maritime and underwater cultural heritage resources should they be discovered during the pipeline laydown area survey.” 
SAHRA disagrees with this statement and insists that the mitigation measures must be included in the EIA, as supported by the HIA from the heritage specialist, and the issued comment from November 2022 must be adhered to. 
Heritage is often an overlooked and ignored resource and measures must be put in place to protect these finite resources should any come to light.