LETTER OF REQUIREMENTS
1) Public participation: this should have been done as part of the HIA however, no proof of public participation such as photos of posters at communal halls and libraries; or proof of consultation with descendents linked to these graves via attendance registers, were provided for. Lastly, since the development is extensive, the developer should have published a notification in a local as well as provincial newspaper to inform interested and affected parties of the development.
2) Field burn of Knight's Hill and Umgala sites: Secondly, in Mr Gavin Anderson's two Heritage Impact Assessments (one for Umgala and one for Knight's Hill) concerning historical, archaeological sites and graves, he indicated that a second visit will be necessary after the two areas were burnt (Umgala and Knight's Hill) to identify if there are more graves (the possibility of more graves cannot be undervalued since graves are heritage sites of high significance, they are all valued as grade IIIA sites).
3) Phase II Heritage Impact Assessment: Considering that a second visit is necessary to identify, map, complete a statement of significance, do a grading recommendation and to list mitigation strategies (for new artefacts and heritage sites or graves which might be discovered after burnt areas was surveyed); as well as the possibility of grave removal and rerouting the development linked to Site KH01, Site KH02 and Site KH03 where development directly impacts on graves at Knight's Hill, a Phase II Heritage Impact Assessment is requested.
4) Regarding palaeontological sites: the chance-find significance of fossils are low but not zero for these two areas (Umgala and Knight's Hill). In the Phase I PIA, done by Dr Alan Smith he states that no significant fossil remains have been documented in the Utrecht area and he recommends that only "Chance-find-protocols" are necessary for palaeontological remains.