Case Decision - 350571

Interim Comment

The Development Applications Unit (DAU) notes the submission of the draft BAR however, the BAR appendices including the heritage studies have not been submitted to the case for commenting. Furthermore, even though the BAR mentions that the area is a World Heritage Site, it does not address what potential heritage may be affected by these activities.

 In order for SAHRA to assess the potential impacts to Maritime Cultural Heritage and Palaeontological Heritage, an assessment of impacts to the Maritime Cultural Heritage and an assessment of impacts to Palaeontological heritage must be undertaken by independent suitably qualified maritime archaeologist and palaeontologist respectively. Please note that Dr Alan Smith is not a qualified heritage practitioner and cannot undertake the complete Maritime Heritage Impact Assessment (MHIA), he is qualified to undertake the Palaentological Impact Assessment (PIA).

If such specialist studies have been commissioned and undertaken by suitably qualified specialists as mentioned in the BAR, these reports must be submitted to the case for commenting.

Please note that the MHIA must also assess the impacts to the OUV's for natural heritage in addition to cultural and maritime heritage as defined in the NHRA.

The SAHRA requests the extension of the BAR application process in terms of 19(1)b of NEMA and the draft BAR to be revised to incorporate the findings of the heritage reports.