Interim Comment
SAHRA reiterates the non-compliance of the HIA with respect to section 38(3) of the NHRA. The submitted HIA does not comply with section 38(3) of the NHRA. No assessment of the impact to identified engravings was conducted, nor is there a background literature review of the proposed development area. Additionally, there is non-compliance with section 38(d) and 38(e) of the NHRA.
SAHRA requests that a field-based HIA is compiled by a qualified heritage specialist (see www.asapa.co.za or www.aphp.org.za for a list of qualified archaeologists). Further comments will be issued upon receipt of the DEIA inclusive of appendices and the above requested report.
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