Interim Comment
The SAHRA, Development Applications Unit (DAU) cannot accept the submitted HIA. The HIA conducted for the project does not comply with section 38(3) of the National Heritage Resources Act, 1999 (Act 25 of 1999) (NHRA) or SAHRAs Minimum Standards for Archaeological Specialists Reports. Please submit a Heritage Impact Assessment that complies with the relevant section of the NHRA and the Minimum Standards referred to above. This must be conducted by relevant qualified heritage specialists. The specialists must submit his/her CV and declaration of independence as part of the HIA.
Furthermore, the Scoping Report indicate that the Heritage assessment was undertaken 2011. Therefore, the HIA report used in the Scoping Report is over 10 years ago, and SAHRA only accepts HIA's that are not more than 5 years old. Therefore, SAHRA requires that the HIA be updated in line with current HIA field study standards by undertaking the following: A field assessment by a suitably qualified archaeologist must be undertaken to determine whether any of the previously identified sites are located within which proximity to the proposed prospecting activities. A track log of the survey must be uploaded on the map.
In terms of palaeontological heritage, the SA Palaeontological Sensitivity Map indicates that the study area has a high Very High fossil sensitivity. Therefore, a field assessment as part of a field-based Phase 1 Palaeontological Assessment is required.
The applicant is advised to extend the EA process in terms of section 19(1)b of the NEMA EIA regulations in order to address this comment. Further comments will be issued upon receipt of the above requested documents.