Case Decision - 355673

Interim Comment

The SAHRA Development Applications Unit (DAU) notes the Preliminary Public Participation Process document.

A Heritage Impact Assessment must be conducted for the 24G application. The HIA must be conducted by a qualified heritage practitioner and must include a Field-based Palaeontological Assessment conducted by a qualified palaeontologist. The Desktop HIA must also include a consolidation of all previous HIAs conducted for the project to ensure that heritage has been adequately assessed for the project. 

The SAHRA DAU requests that an assessment of the impact to heritage resources that complies with section 38(3) of the NHRA as required by section 38(8) of the NHRA must be conducted as part of the EA process. The HIA must include an archaeological component. 

The field-based archaeological component of the HIA must be conducted by a qualified archaeologist and must 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 Minimum Standards refer to a Letter of Recommendation for Exemption for further studies should the specialist deem it appropriate. SAHRA reserves the right to insist on a field-based assessment should the Letter of Recommendation not provide ample information to make an informed comment.

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.

In terms of palaeontological heritage, the SA Palaeontological Sensitivity Map indicates that parts of the study area have Low and Very High fossil sensitivity, therefore a field-based Palaeontological  Impact Assessment is required. The SAHRA 2012 Minimum Standards: Palaeontological Component of Heritage Impact Assessments makes reference to a Letter of Recommendation for Exemption that is to be submitted if there is no likelihood that heritage sites will be impacted. SAHRA awaits the above palaeontological desktop study/ Letter of Recommendation for Exemption completed by a qualified palaeontologist to be submitted before further comments can be issued.

The Environmental Report and all appendices must be submitted so that an informed comment may be issued.