Case Decision - 354675

Interim Comment 

The South African Heritage Resources Agency (SAHRA) cannot accept the Letter of Recommendation for Exemption from undertaking a Heritage Impact Assessment Letter submitted by Jonathan Kaplan. The images provided show a burial site(s) protected by a fence and structures. However, the Letter does not provide enough information for SAHRA to determine whether resources are protected by the National Heritage Resources Act (NHRA), Act 1999 no. 25 or will be impacted by development activities. The locations (or sensitivity map) of the burial site(s) and structures in relations to the proposed development has not been indicated. Mitigations measures have not been provided for these resources. 

Therefore, SAHRA requires an assessment must include an assessment of the impact to archaeological and palaeontological resources. The field-based assessment of archaeological resources must be conducted by a qualified archaeologist and the report comply with the SAHRA 2007 Minimum Standards: Archaeological and Palaeontological Components of Impact Assessment Reports (see www.asapa.co.za or www.aphp.org.za for a list of qualified archaeologists). The assessment must include the track logs of the area to be surveyed.

The proposed development is located within an area of insignificant/zero and moderate Palaeontological Sensitivity as per the SAHRIS PalaeoSensitivity map. As such, desktop study is required. The assessment must be undertaken by a qualified palaeontologist. (See https://www.palaeosa.org/heritage-practitioners.html for a list of qualified palaeontologists). The report must comply with the 2012 Minimum Standards: Palaeontological Components of Heritage Impact Assessments. The minimum standards make reference to a Letter of Recommendation for Exemption that is to be submitted if there is no likelihood that palaeontological sites will be impacted.

Any other heritage resources as defined in section 3 of the NHRA that may be impacted, such as built structures over 60 years old, sites of cultural significance associated with oral histories, burial grounds and graves, graves of victims of conflict, and cultural landscapes or viewscapes must also be assessed.

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 reports.