FINAL INTEGRATED HERITAGE IMPACT ASSESSMENT In terms of Section 38(8) of the NHRA for a PROPOSED ABALONE FARM ON ERF 385,

DEA Ref: HWC Ref: 18090507SB1002E

Prepared by Katie Smuts

For Pearly Beach Seafarm (Pty) Ltd

15 September 2019

THE INDEPENDENT PERSON WHO COMPILED A SPECIALIST REPORT OR UNDERTOOK A SPECIALIST PROCESS

I Kathryn Smuts, as the appointed independent specialist hereby declare that I: • act/ed as the independent specialist in this application; • regard the information contained in this report as it relates to my specialist input/study to be true and correct, and • do not have and will not have any financial interest in the undertaking of the activity, other than remuneration for work performed in terms of the NEMA, the Environmental Impact Assessment Regulations, 2014 and any specific environmental management Act; • have and will not have no vested interest in the proposed activity proceeding; • have disclosed, to the applicant, EAP and competent authority, any material information that have or may have the potential to influence the decision of the competent authority or the objectivity of any report, plan or document required in terms of the NEMA, the Environmental Impact Assessment Regulations, 2014 and any specific environmental management Act; • am fully aware of and meet the responsibilities in terms of NEMA, the Environmental Impact Assessment Regulations, 2014 (specifically in terms of regulation 13 of GN No. R. 594) and any specific environmental management Act, and that failure to comply with these requirements may constitute and result in disqualification; • have ensured that information containing all relevant facts in respect of the specialist input/study was distributed or made available to interested and affected parties and the public and that participation by interested and affected parties was facilitated in such a manner that all interested and affected parties were provided with a reasonable opportunity to participate and to provide comments on the specialist input/study; • have ensured that the comments of all interested and affected parties on the specialist input/study were considered, recorded and submitted to the competent authority in respect of the application; • have ensured that the names of all interested and affected parties that participated in terms of the specialist input/study were recorded in the register of interested and affected parties who participated in the public participation process; • have provided the competent authority with access to all information at my disposal regarding the application, whether such information is favourable to the applicant or not; and • am aware that a false declaration is an offence in terms of regulation 48 of GN No. R. 594.

Kathryn Smuts Signature of the specialist

01/07/2019 Date

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EXECUTIVE SUMMARY 1. Site Name The applicant, Pearly Beach Seafarm (Pty) Ltd has proposed the establishment of an aquaculture facility for the production of Abalone on Remainder of Farm 385, Pearly Beach, Overstrand Municipality, District.

2. Location The project site is located 1km west of Pearly Beach, 22km east of and some 600m east of the Uilkraalsmond Nature Reserve. The project site comprises Remainder of Farm 385, Pearly Beach, Overstrand Municipality, Overberg District. The site is bounded by the coast at the southern extent to the to the north east.

3. Locality Plan

Locality Plan showing proposed project site in red.

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4. Description of Proposed Development Pearly Beach Seafarm (Pty) Ltd has proposed the establishment of an aquaculture facility for the production of Abalone on Remainder of Farm 385, Pearly Beach, Overstrand Municipality, Overberg District. The development, which is proposed to be undertaken in 6 phases of 160 tons / approximately 2.5 ha, will eventually see the production of 1000 tons of abalone over an area of approximately 19 ha.

The development will entail the following: • Grow out area (Phases 1 to 6) • Processing area including canning, freezing, live packing &drying • Algae / Seaweed culture area • Administration block • 2 ha solar array generating approximately 2.5 megawatts • Hatchery (approx. 7500 m2) • Approx. 9 dwellings for management personnel • Intake and effluent lines (3 intake lines capable of 3600 m3/ hour each), one effluent line to discharge in line with conditions of the Coastal Waters Discharge Permit (CWDP) • Access via existing jeep track on east boundary, to be upgraded to a hardened dirt road o Will not affect public access to coastline • Additional infrastructure i.e ablutions, canteen, sump & pump house, workshops, power transmissions room for generators, freshwater storage etc. • The total development footprint will be approximately 5 000m2

During the assessment process, the layout of the proposed facility was altered such that no significant archaeological heritage resources will be directly impacted.

5. Heritage Resources Identified This integrated HIA comprises a collation of the Archaeological Impact Assessment (Kaplan, 2019; Appendix 1) and Visual Impact Assessment (Oberholzer and Lawson, 2019; Appendix 2) reports compiled pertaining to identified heritage resources. These Impact Assessment reports were compiled in response to the 10 October 2018 Heritage Western Cape (HWC) response to the NID (Appendix 3); no Palaeontological Impact Assessment was requested.

The archaeological survey identified several archaeological sites consisting of artefact/marine shell scatters within and immediately adjacent to the development footprint. Eleven Later Stone Age sites were

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identified, comprising four sites of medium significance and six of low significance. All the sites consisted of shell middens or scatters of shell with varying quantities of associated artefactual material. No bone or ostrich eggshell beads or fragments were identified, with only a single sherd of indigenous pottery recorded. No historical archaeology was identified, nor were any graves, either formal or informal.

The Visual Impact Assessment identified the rural landscape and the scenic route of the R43 as heritage resources sensitive to visual impacts.

6. Anticipated Impacts on Heritage Resources Mitigation was recommended in the AIA (Kaplan, 2019) for the four medium significance sites, by way of no- go buffer zones of varying extent, or excavation prior to development. A redesign of the layout takes cognisance of the proposed buffers, but the proximity of infrastructure to these sites means that impacts to them during the construction and operation of the facility could still occur. Given the modified proposed location of the bulk of the infrastructure along the shoreline, in the area where the sites are prevalent, it is likely that, without mitigation through excavation, impacts to these sites will be moderate to high.

No archaeological impacts are anticipated from the development of the north eastern extent of site, where the accommodation facilities and other auxiliary structures are to be located due to the general paucity of archaeological sites known to exist at this distance from the coastline in this region.

The VIA identified that the visual impact significance for the full 6 phases of the Abalone Farm would be medium to high without mitigation and medium with mitigation, while the solar PV plant and proposed single storey staff houses were both assessed as being low both before and after mitigation. The effect of lights at night from buildings and lighting masts on the perimeter will add to visual impact significance. The most significant impacts would be experienced along the R43, a proposed Scenic Route, and from the beach. The visual impact significance of the abalone farm would be long term to permanent and would only reduce to low with mitigation if the facilities are decommissioned after its operational life and the site rehabilitated.

7. Recommendations The following recommendations were made in terms of impacts to the archaeological heritage resources:

• Test excavations/sampling of deposits must be undertaken at PBAF512 (S34°39.579' E19°28.146') prior to construction activities commencing. Alternatively, a buffer of 10m must be established around the site.

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• Test excavations/sampling of deposits must be conducted at PBAF612 (S34°39.583' E19°28.123') prior to construction activities commencing. Alternatively, a buffer of 10m must be established around the site. • PBAF1012 (S34°39.551' E19°28.005') must be sampled prior to construction activities commending. Alternatively, a buffer of 10m must be established around the site. • PBAF1612 (S34°39.563' E19°27.990') must be sampled prior to construction activities commending. Alternatively, a buffer of 15m must be established around the site.

The following recommendations are made in terms of impacts to the archaeological heritage resources, in light of the remaining threat posed by the proximity of the facility to the high significance sites:

• The sites listed above, PBAF512 (S34°39.579' E19°28.146'), PBAF612 (S34°39.583' E19°28.123'), PBAF1012 (S34°39.551' E19°28.005'), PBAF1612 (S34°39.563' E19°27.990'), must be subject to test excavation under a workplan prior to development. A qualified archaeologist must supervise the erection of protective fencing once sampling has been undertaken. All fences should observe the recommended buffers for each site (10m for PBAF512, PBAF612 and PBAF1012, 15m for PBAF1612) and no development activities should occur within those buffers. • Vegetation clearing operations, particularly in the coastal foredunes, must be monitored by a professional archaeologist. If any archaeological deposits are exposed, these might need to shovel tested under a Work Plan permit, to determine the potential significance of the deposits. • Bulk earthworks (e. g. for water, electricity, sewerage, &intake & discharge pipelines) must be monitored by a professional archaeologist. This can be done in consultation with the Environmental Control Officer (ECO) who must be on site during the Construction Phase of the project. The archaeologist does not need to be on site permanently, but should visit the site at least once a week during the Construction Phase, or when the need arises. If any archaeological deposits are exposed during these activities, these may need to be sampled or excavated to determine the significance of the deposits. • Excavations for building foundations (e. g. proposed managers house, administration offices, intake & effluent area) must be monitored by a professional archaeologist. If any archaeological deposits are exposed during these activities, these may need to be sampled or excavated to determine the significance of the deposits. • If any unmarked Khoesan graves are uncovered or exposed during bulk earthworks and excavations, these must immediately be reported to the contracted archaeologist or Heritage Western Cape (Att: Mr Andrew September 021 483 9685). In the case of human burials, these will have to be removed

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under a permit issued by HWC. • The above recommendations must form part of the Construction Environmental Management Plan (EMP) for the proposed development.

The following recommendations are made in terms of visual impacts to the cultural landscape and scenic routes:

Planning and Design Mitigation Measures • Maintain a 42m minimum setback from the high water mark (HWM) for all structures, including paddle ponds, pump house, electrical rooms, parking and fencing, to provide adequate space for coastal dunes and screening of large scale structures when viewed from the beach. (Fig. 8). • Maintain a 100m minimum setback from the HWM for all other development, to minimize visibility of proposed 2-storey structures from the beach, and for coastal legislation purposes. • Maintain a 60m minimum visual setback from the R43 property boundary to minimize visibility of the proposed development from the scenic / tourist route, (Fig. 7). • Reduce the height of the feed manufacture and storage building (Building 'D') from 12m to 8.5m. • Restrict the height of all buildings in the proposed development to 8.5m (eaves height) and 10.0m (top of gable, or roof line), measured from natural ground level. • Construct a planted dune along the R43 boundary with a minimum height of 7.0m above road level. Spoil material from the earthworks for the development could be used. • Except for gate posts at the entrance, no solid walls on the R43 to be permitted. Only see-through type fencing to be used, in order to retain the rural character of the area. • Avoid locating powerlines on the crests of dunes or on high ground, where they will be visible on the skyline. • Fit all security and perimeter lighting with sensors so that these are only activated by movement, to minimize the visual impact of lighting at night on the rural surroundings. • Maintain existing topographic ridges and high points, where possible to maintain the visual integrity of the skyline seen from surrounding areas. • Locate large structures in low-lying positions of the site, where possible, and minimize earthworks and disturbance to the site by taking the topography into account. Consider locating Platforms 3A and 3B further north to avoid high ground and excessive earthworks. • Provide an earthworks plan, indicating levels of buildings, platforms and roads, and all cut and fill slopes, including embankment gradients. The earthworks plan to be submitted as part of the Basic Assessment submission.

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• Consider grouping the proposed staff houses around a werf or courtyard, to create a more rural village character, instead of the current 'township' layout. Consider locating the housing complex in a NW-SE direction in keeping with the topography. • Locate the solar PV arrays in a low-lying area, off any dune ridges, and in sympathy with the topography. • Reduce the visibility of proposed seafarm buildings by using muted colours for wall and roofs. • Screen buildings and infrastructure with planted earth berms (artificial dunes), where possible. • Keep access roads as narrow as possible, as currently proposed, and use existing tracks where appropriate.

A recommendation to Increase the height of the frontal dunes to a minimum of 6.5m above MSL and stabilize the dunes with suitable planting to provide visual screening and coastal protection is not supported in terms of the irreparable damage such an action would have on the archaeological material located in that frontal dune area.

Construction Mitigation Measures • Locate the construction camp and related storage/stockpile areas in visually unobtrusive positions on the site, where these are not visible from the beach or R43. • Provide measures to prevent wind-blown sand, dust and litter as part of the EMPr. • Locate pipelines and powerlines underground, where possible. • The EMPr to be monitored by an Environmental Control Officer (ECO).

Operation / Lighting Mitigation Measures • Use infrared technology or movement sensors for perimeter security, to minimize the effect of ambient lighting at night on the rural surroundings. • Keep general outdoor lighting as unobtrusive as possible through use of low-level bollard type lights, where needed, such as parking areas and footpaths. • Use discrete external signage and avoid commercial advertising or billboard-type signs. Fix signs to buildings or walls, if possible, to avoid the visual clutter of signposts.

Decommissioning Mitigation Measures • On closure of the abalone operation remove all above-ground buildings and structures and recycle building materials. • Rip and regrade all hardened platform areas and access roads that are no longer required.

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• Regrade and revegetate exposed or disturbed areas and return these to natural strandveld to blend with the surroundings. (Revegetation measures to be prescribed by the vegetation/ biodiversity specialist).

Monitoring Recommendations • Construction Phase Monitoring: Ensure that visual mitigation measures are included as part of the EMPr, monitored by an ECO, including the siting of the construction camp and stockpiles, dust suppression and litter control measures, with regular reporting to an environmental management team.

• Operation Phase Monitoring: Ensure that visual mitigation measures are monitored by management on an on-going basis, including the control of signage, lighting and wastes on the site, with interim inspections by a delegated ECO.

• Decommissioning Phase Monitoring: Ensure that procedures for the removal of structures and stockpiles during decommissioning are implemented, including recycling of materials and rehabilitation of the site to a visually acceptable standard as prescribed in a rehabilitation plan, and signed off by the delegated authority.

8. Author/s and Date HIA compiled by Kathryn Smuts 15 September 2019

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Katie Smuts holds an MPhil from UCT in Archaeology (History and Archaeology of the Western Cape; 2012), having specialised in archaeological analysis of historic built fabric and forms. Prior to that, her BA (Hons), obtained from UCT with distinction in 1999, was focused on analysis of depictions of human figures in the rock art of the Western Cape.

Katie has worked both as a commercial archaeologist and as a Heritage Officer for the national Heritage Agency, SAHRA. Katie was promoted to Manager of the National Inventory at SAHRA, where she was responsible for the maintenance of the country’s online heritage management platform and heritage resource database, SAHRIS (the South African Heritage Resources Information System).

Following her time at SAHRA, Katie returned to heritage consultation, working first for CTS Heritage and thereafter as a freelance heritage practitioner and archaeological consultant. As part of consulting work, Katie was responsible for drafting Heritage Impact Assessments, Archaeological Impact Assessments, Heritage Inventories, heritage scoping reports and heritage components for Strategic Environmental Assessments, Environmental Management Frameworks and similar planning initiatives. Katie is currently Senior Heritage Practitioner at Rennie Scurr Adendorff Architects where she is responsible for heritage and archaeological research and report writing pertaining to Section 27, 31, 34, 35 and 38 applications.

Katie serves on the Executive Council of the Association of Southern African Professional Archaeologists (ASAPA), and holds accreditation in rock art, coastal shell middens, Stone Age archaeology and grave relocation. She has been a member of the Association of Professional Heritage Practitioners (APHP) since 2015, a member of the Southern African Museums Association (SAMA) since 2013, and is currently serving as treasurer of the Heritage Association of Southern (HASA). She is Chair of the Overstrand Heritage and Aesthetics Committee (OHAC) and a former Chair of the Stanford Heritage Committee (SHC).

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Table of Contents 1. INTRODUCTION ...... 1 1.1. Background Information on the Project ...... 1 1.2. Description of the Project Site and Affected Environment ...... 1 2. METHODOLOGY ...... 5 2.1. Purpose of HIA ...... 5 2.2. Summary of Steps Followed ...... 5 2.3. Assumptions and Limitations ...... 5 3. HISTORY AND EVOLUTION OF THE SITE AND CONTEXT ...... 6 3.1. Definition of the Property ...... 6 3.2. Geology, Geomorphology, Climate and Vegetation ...... 6 3.3. Paleontological, Archaeological and Historical Background of the Pearly Beach area ...... 6 3.3.1. Palaeontological Background ...... 6 3.3.2. Archaeological Background ...... 7 3.3.3. Historical Background ...... 9 3.3.4. Burials ...... 9 3.3.5. Cultural Landscape ...... 10 3.3.6. Scenic Route ...... 11 4. IDENTIFICATION OF HERITAGE RESOURCES ...... 14 4.1. Summary of Findings of Specialist Reports ...... 14 4.1.1. Archaeological Impact Assessment ...... 14 4.1.2. Visual Impact Assessment ...... 14 4.2. Heritage Resources identified ...... 15 4.2.1. Archaeology ...... 15 4.2.1.1. Mapping of Archaeological Heritage Resources...... 20 4.2.2. Visual Receptors, Scenic Routes and Cultural Landscapes ...... 24 4.2.2.1. Mapping of Visual Impacts ...... 27 5. ASSESSMENT OF THE IMPACT OF THE DEVELOPMENT ...... 37 5.1. Assessment of Impact to Archaeological Heritage Resources ...... 37 5.1.1. Visual Impacts, Including Cultural Landscapes and Scenic Drives ...... 38 5.2. Cumulative Impacts ...... 44 5.3. Sustainable Social and Economic Benefit ...... 47 5.4. Proposed Development Alternatives ...... 47 6. RESULTS OF PUBLIC CONSULTATION ...... 47 7. CONCLUSION AND RECOMMENDATIONS ...... 52 7.1. Conclusion ...... 52 7.2. Recommendations ...... 53 8. REFERENCES...... 57 9. APPENDICES ...... 59

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List of Figures Figure 1. The location of the proposed Pearly Beach Abalone Farm on Farm 385, west of Pearly Beach, Overstrand Municipality. 3419CB Gansbaai (Chief Director Surveys and Mapping) ...... 1 Figure 2. Proposed development site, Farm 385, Pearly Beach...... 2 Figure 3. Image showing proposed layout of the Pearly Beach Abalone Farm, Farm 385...... 3 Figure 4. 3D model of the entrance area infrastructure (Oberholzer and Lawson, 2019: 37)...... 4 Figure 5. 3D model of the production area infrastructure (Oberholzer and Lawson, 2019: 39)...... 4 Figure 6. Landscape Significance Map; red circle indicates study area (Baumann et al., 2009: 38)...... 11 Figure 7. All known heritage sites in the immediate vicinity of the proposed project area. All of these are archaeological (See Table 1)...... 12 Figure 8. The locations of the historic Awila werf and the more recent Farm 227 werf relative to the proposed development...... 13 Figure 9. PBAF213, outside the development area (Kaplan, 2019)...... 16 Figure 10. Thin walled, coarse tempered, unburnished, undecorated pot sherds (from a single vessel) recorded at PBAF313 (Kaplan, 2019)...... 16 Figure 11. PBAF512, on an east facing slope (Kaplan, 2019)...... 16 Figure 12. North facing aspect of PBAF1012 (Kaplan, 2019)...... 16 Figure 13. West facing aspect of PBAF1012 dune mound (Kaplan, 2019)...... 17 Figure 14. Detail of PBAF1012 on prominent dune mound (Kaplan, 2019)...... 17 Figure 15. PBAF1612 on an east facing slope (Kaplan, 2019)...... 17 Figure 16. Detail of PBAF1612 (Kaplan, 2019) ...... 17 Figure 17. Map showing area of archaeological survey relative to greater project area. Surveyed area extends c. 950m from the high tide line...... 20 Figure 18. Trackpaths and sites identified during field survey (Table 2)...... 21 Figure 19. Detail of sites with the recommended buffers indicated around the Grade IIIB sites. Sites PBAF512, 612 and 1012 have recommended buffers of 10m, while PBAF1612 has a recommended buffer or 15m. .... 22 Figure 20. Significant archaeological sites shown with buffers indicated, overlaid on SDP (Gericke, 2019). ... 23 Figure 21. Dunes and coastal dune thicket at southern extent of the site (Oberholzer and Lawson, 2019: 14)...... 24 Figure 22. Existing house to east of development area (Oberholzer and Lawson, 2019: 14)...... 24 Figure 23. View along R43 with an existing power line parallel to the road (Oberholzer and Lawson, 2019: 15)...... 25 Figure 24. VIA fieldwork and viewpoints map (Oberholzer and Lawson, 2019: 30)...... 27 Figure 25. Landscape elements near the proposed development with 20m contours depicted (Oberholzer and Lawson, 2019: 31)...... 28 Figure 26. Combined Viewshed Analysis (Oberholzer and Lawson, 2019: 34)...... 29 Figure 27. Viewshed Analysis of entrance area infrastructure (Oberholzer and Lawson, 2019: 32)...... 30 Figure 28. Viewshed Analysis of production area infrastructure (Oberholzer and Lawson, 2019: 32)...... 31 Figure 29. Photomontages of the proposed development from Viewpoints 1 and 2 (Oberholzer and Lawson, 2019: 43)...... 32 Figure 30. Photomontages of the proposed development from Viewpoints 3 and 4 (Oberholzer and Lawson, 2019: 44)...... 33 Figure 31. Photomontages of the proposed development from Viewpoints 5 and 6 (Oberholzer and Lawson, 2019: 45)...... 34 Figure 32. Photomontages of the proposed development from Viewpoints 7 and 8 (Oberholzer and Lawson,

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2019: 46)...... 35 Figure 33. Photomontages of the proposed development from Viewpoints 9 and11 (Oberholzer and Lawson, 2019: 47)...... 36 Figure 34. Simulated night view from VP4 on the beach opposite the site (Oberholzer and Lawson, 2019: 48)...... 38 Figure 35. Proposed 60m setback line for entrance area infrastructure; 5m contours depicted (Oberholzer and Lawson, 2019: 36)...... 41 Figure 36. Observed setback lines for production area infrastructure; 5m contours depicted (Oberholzer and Lawson, 2019: 38)...... 42 Figure 37.Proposed mitigation measures for production area (Oberholzer and Lawson, 2019: 42)...... 43 Figure 38. Proposed mitigation measures for production area (Oberholzer and Lawson, 2019: 41)...... 43 Figure 39. Map of other abalone farming facilities in the region...... 46

List of Tables Table 1. Sites identified in Farm 385 field survey (Kaplan, 2019) ...... 18 Table 2. Potential Visibility of proposed development (Oberholzer and Lawson, 2019: 18)...... 25 Table 3. Visual Impact Intensity (severity) of full development phases ...... 26 Table 4. Impacts on significant physical archaeological resources ...... 37 Table 5. Visual impacts of proposed development on heritage resources during the construction phase 39 Table 6. Visual impacts of proposed development on heritage resources during the operational phase . 40 Table 7. Cumulative impacts to archaeological heritage resources ...... 44 Table 8. Cumulative visual impacts to heritage indicators in the region ...... 45

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1. INTRODUCTION 1.1. Background Information on the Project Pearly Beach Seafarm (Pty) Ltd has proposed the establishment of an aquaculture facility for the production of Abalone on Remainder of Farm 385, Pearly Beach, Overstrand Municipality, Overberg District. The development, which is proposed to be undertaken in 6 phases of 160 tons / approximately 2.5 ha, will eventually see the production of 1000 tons of abalone over an area of approximately 19 ha.

The development will entail the following: • Grow out area (Phases 1 to 6) • Processing area including canning, freezing, live packing &drying • Algae / Seaweed culture area • Administration block • 2 ha solar array generating approximately 2.5 megawatts • Hatchery (approx. 7500 m2) • Approx. 9 dwellings for management personnel • Intake and effluent lines (3 intake lines capable of 3600 m3/ hour each), one effluent line to discharge in line with conditions of the Coastal Waters Discharge Permit (CWDP) • Access via existing jeep track on east boundary, to be upgraded to a hardened dirt road o Will not affect public access to coastline • Additional infrastructure i.e ablutions, canteen, sump & pump house, workshops, power transmissions room for generators, freshwater storage etc. • The total development footprint will be approximately 5 000m2

A table providing further details is available in Appendix 1.

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1.2. Description of the Project Site and Affected Environment The project site is located 1km west of Pearly Beach, 22km east of Gansbaai and some 600m east of the Uilkraalsmond Nature Reserve . The project site comprises Remainder of Farm 385, Pearly Beach, Overstrand Municipality, Overberg District (Figure 1, Figure 2, Figure 3). The site is bounded at the southern extent by the coastline, at a sandy stretch of beach, and the R43 to the north east.

The site comprises a series of fairly high, stable, undulating dunes, the southernmost of which are infested with alien Rooikrantz vegetation. The back dune area is similarly densely vegetated, mostly covered with natural grasses and pristine . Wind erosion in the western sector has exposed a hard surface area of calcrete. Evidence of a recent fire through the area is widespread. The north eastern portion of the site is covered in a mix of both natural vegetation, and alien Rooikrantz.

Kaplan (2019) describes existing infrastructure in the form of old farm roads, barely visible tracks and footpaths, a concrete water reservoir in the north east, concrete fence poles, rusted wire fencing, and an old windmill on a slight hill slope in the north western portion of the site. Tracks and footpaths crossing the site, piles of shucked abalone shells and litter show use of the site by abalone poachers.

Figure 1. The location of the proposed Pearly Beach Abalone Farm on Farm 385, west of Pearly Beach, Overstrand Municipality. 3419CB Gansbaai (Chief Director Surveys and Mapping)

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Figure 2. Proposed development site, Farm 385, Pearly Beach.

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Figure 3. Image showing proposed layout of the Pearly Beach Abalone Farm, Farm 385.

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Figure 4. 3D model of the entrance area infrastructure (Oberholzer and Lawson, 2019: 37).

Figure 5. 3D model of the production area infrastructure (Oberholzer and Lawson, 2019: 39).

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2. METHODOLOGY 2.1. Purpose of HIA The purpose of this Heritage Impact Assessment (HIA) is to satisfy the requirements of section 38(8), and therefore section 38(3) of the National Heritage Resources Act (Act 25 of 1999). A NID was submitted for this project, and a “Response to NID” letter was received from Heritage Western Cape (HWC) dated 10 October. In that response (Appendix 3), HWC required that an HIA be submitted with specific reference to: - Visual impacts of the proposed development - Impacts to archaeological heritage resources

2.2. Summary of Steps Followed • An archaeologist conducted an assessment of the archaeological resources likely to be impacted by the proposed development1; • A Visual Impact Assessment was undertaken2; • No Social Impact Assessment was undertaken as part of this BAR. • The identified resources were mapped and assessed to evaluate their heritage significance in terms of the grading system outlined in section 3 of the NHRA (Act 25 of 1999); • Impacts to the cultural landscape were considered and evaluated; • Specialist findings were collated into an integrated Heritage Impact Assessment (HIA).

2.3. Assumptions and Limitations Integrated Heritage Impact Assessment: • It is assumed that the specialist reports utilised for the integrated heritage assessment are comprehensive and reflective of the full extent of the specialists’ knowledge and expertise; • The HIA has been compiled based on the contents of the specialist reports and desk-based research.

Archaeological Impact Assessment: • The frontal coastal dunes are infested with alien Rooikrantz resulting in very low archaeological visibility. Visual Impact Assessment: • Some assumptions were made about the project layout and design as architectural details of the buildings will only become available over time as the phases are rolled out.

1 (Kaplan, J. 2019. A Baseline Archaeological Study: Proposed Abalone Farm on Erf 385, Pearly Beach Western Cape. Unpublished report. Rondebosch: ACRM) 2 (Oberholzer, B. 2019. Visual Impact Assessment Report: Proposed Abalone Farm and Abalone Processing Facility, on Portion of Remainder of Farm 385 near Pearly Beach, Overstrand, Western Cape. Unpublished report. Stanford: BOLA)

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3. HISTORY AND EVOLUTION OF THE SITE AND CONTEXT 3.1. Definition of the Property Pearly Beach Seafarm (Pty) Ltd has proposed the establishment of an aquaculture facility for the production of Abalone on Remainder of Farm 385, Pearly Beach, Overstrand Municipality. The project site is located 1km west of Pearly Beach, 22km east of Gansbaai and some 600m east of the Uilkraalsmond Nature Reserve.

3.2. Geology, Geomorphology, Climate and Vegetation The proposed abalone farm is situated on a piece of land that extends from the coast at the south to the R43 at the north. The bedrock in this area comprises the Peninsula formation of the Table Mountain Group, which is overlain by consolidated to semi-consolidated aeolianite, calcareous sand, and calcrete lenses of the Waenhuiskrans Formation, with unconsolidated dune sands of the Strandveld Formation nearest the coast (SAHRIS, 2014). Undulating dunes under dense thickets of Rooikrantz and patches of indigenous fynbos characterise the site.

The site falls within the Fynbos Biome. The indigenous vegetation is in this area comprises the South Strandveld Bioregion, a strictly coastal bioregion that occurs in patches between and Port Elizabeth, and South Coast Fynbos Bioregion, which occurs mainly on the flats between and Mossel Bay (Rutherford et al. 2006). The archaeologist for this project has previously reported on the extensive transformation of this region as a result of long-term grazing (Kaplan 2003).

The project site falls within the Cape Mediterranean-type climatic zone, with hot, dry summers and cool, wet winters, although this region does experience some limited variability in the seasonality of rainfall. The peak rainfall period is April to September, and mean annual precipitation for the region is between 450mm and 550mm (Mucina et al. 2006).

3.3. Paleontological, Archaeological and Historical Background of the Pearly Beach area 3.3.1. Palaeontological Background According to the SAHRIS Palaeosensitivity map, the area is underlain by geological deposits of very high fossil sensitivity (SAHRIS 2014). The geology comprises Peninsula formation of the Table Mountain Group, which is overlain by partially cemented aeolianites of the Waenhuiskrans Formation of the Strandveld Formation. The mantling of these superficial sands is very thick, in this area.

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3.3.2. Archaeological Background The Overstrand coastline and adjacent interior has exceptionally rich archaeological heritage, having been inhabited from at least the Middle Stone Age, as evidenced by excavations at Die Kelders (Schweitzer, 1979; Marean, 2000; Grine 2000). This occupation continued up until the Later Stone Age and into the historical period and is characterised by shell middens, open sites and cave sites.

Ancestral San populations inhabited the area over the past 30 000 years, exploiting the abundant shellfish that is available along the rocky shoreline, and making repeated trips to the region as part of their seasonal transhumance that cycled between inland and the coast. Around 2 000 years ago, these hunter-gatherers were joined by the Khoekhoen, pastoralists with sheep and cattle. These herders followed the same transhumant pattern as the hunter-gatherers and exploited the same resources, but introduced a new economic system, together with different settlement patterns and new industries, including ceramic technology. These Khoekhoen traded livestock with the VOC Company outposts established in the Overberg during the early 18th century (Hart and Halkett, 2012).

The region has been investigated by archaeologists since the 1940s when Professor John Goodwin undertook a series of observations of the fishtraps along the coast (Goodwin, 1946). The first formal excavations, however, only took place in the 1970s when archaeologists from the South African Museum were exploring the prehistory of the southern Cape; these researchers remained active throughout the 1970s and 1980s. Excavations at Die Kelders in Gansbaai produced important finds of early pottery and domesticates as well as MSA layers more than 40 000 years old (Schweitzer, 1979). Further survey and excavation of shell middens was undertaken in the Pearly Beach area, providing material for a regional study of subsistence strategies of Stone Age coastal populations (Avery, 1974).

Avery’s study (1974) showed that while sites might be found up to two kilometres inland, they clustered near rocky shorelines, with no sites visible along sandy beaches. Avery (1976) suggested that these sites were processing sites, utilised by Khoekhoen and San, to shuck and dry shellfish for transportation inland. A 1984 study of the region (Hall, 1984) showed that most Stone Age sites in this region were located directly on the shoreline or along the edge of the inland dunefield on prominent dunes overlooking the coastal plains. More recent work has corroborated these findings through extensive survey work across the coastal regions of the south, west and north coast of (reported on in Hart and Halkett 2012). Further local studies show that sites are predominantly located within deflation bays and inland edges of the dune fields which provided easy access to fresh water, grazing and marine resources (Hart 2006; Hart and Halkett, 2012; Kaplan 2003).

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Previous HIAs completed in Pearly Beach include two surveys for a Waste Water Treatment Works and one for a housing estate; all of these surveys were conducted on land immediately adjacent to the proposed development area. Of these, the two WWTW surveys found no archaeological material (Kaplan 2003; Webley 2014). Kaplan (2003) noted the extensive alien vegetation on the site, and was informed by the applicant that the area had been under grazing since the 1940s and was extensively transformed as a result. The survey for the housing estate, which took place on a portion of Farm 227, identified large concentrations of LSA material in the immediate coastal dunes, including shellfish and bone remains, with artefactual material dominated by large quartzite manuports and low quantities of silcrete waste (Hart, 2006).

Known sites in the immediate vicinity comprise shell middens with associated stone artefacts that have been identified in the course of impact assessment surveys. All of these sites have been recommended as Grade IIIC heritage resources of low significance (

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). The spatial distribution of these known sites further supports the expected patterning of sites in this region, and shows they are restricted to the area immediately adjacent to the coastline (Figure 7).

3.3.3. Historical Background When the VOC first began expanding into the Overstrand region, the area was dominated by Khoekhoen pastoralists, who traded livestock with the outposts established there in the 1730s and 1740s (Baumann et al. 2009). The first loan farms were granted in the early 18th Century, and within a short time, European farmers were widely settled in the landscape. The competition for access to grazing, the disruption of traditional lifeways, and the introduction of previously unknown diseases had immediate and damaging consequences for the indigenous herders such that, by the mid 19th Century, most were living at mission stations or had been taken on as farm labourers.

Pearly Beach was established in the 19th Century, originally serving as a meeting place for trekboers who exploited the freshwater supplied by the Uilenkraals, Hagelkraal and Buffelsjags Rivers (Baumann et al., 2009). Development of a settlement was slow, and few permanent dwellings were built in the area aside from fisherman’s cottages until the 20th Century. Following the construction of the R43, and the growing popularity of Hermanus as a holiday destination during and after World War II, however, settlement of the area increased (Ibid.).

The property, Remainder Farm 385, is a recent deduction from the historic farms Lang Gelegen 227. The farm has no historic structures on it, and it carries no heritage significance (Baumann et al., 2009). Indeed, none of the adjacent farms appear to have historic structures to the south of the R43. The nearby farm Awila 223, is proposed as a Grade 3B heritage resource due to its historical setting at the confluence of two major road links, archaeological potential in terms of early pioneer farming lifeways and as an example of an early C19th longhouse with banded corrugated iron roof (Baumann et al, 2009b), but this structure is located some 2.5km from the proposed development area (Figure 8).

3.3.4. Burials Unmarked pre-colonial graves are known from this area and are most likely to be found along the coastline. Colonial burials are likely to be associated with older farm werfs, or settlements, although more isolated historic features such as old stockposts and other, less formal settlements might also contain burials. Sailors who were shipwrecked along the coast were known to have been buried along sandy beaches above the hightide mark, and these kinds of burials could be present in the region.

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3.3.5. Cultural Landscape The cultural landscape of the area comprises several elements. First of these is the spectacular natural beauty provided by the backdrop of the shoreline, coastal plains and mountains, and the area is renowned for its scenic quality, birdlife and endemic fynbos. A further layer is provided by traces of human habitation going back over 40 000 years, and contributes to a pre-colonial, Stone Age cultural landscape, evidenced in visible archaeological traces such as shell middens and fishtraps. More recent anthropogenic layering is provided by the rural farmland, characterised by historic farm houses, historic farm boundaries and land uses i.e. fenced grazing, vineyards etc, and by historic settlements such as Stanford and Bardskeedersbos. This interplay of natural and cultural landscapes lends the Overstrand its sense of place, and is a highly significant local heritage resource in its own right.

Overlaying these historic features is the sprawl of recent – largely unchecked – development along the coastal strip, particularly evident in small towns such as Pearly Beach (Baumann et al., 2009). Rampant recent development on the Overstrand coastline has reduced the prevalence and significance of extant cultural landscapes within the region in and around the many coastal villages. Further to development degrading the cultural landscape, abalone poaching activities have marred many undeveloped sites, through the creation of paths through vegetation, accumulations of shucked shellfish and litter and general negative impacts the natural heritage landscape and sense of place (Kaplan, 2019).

The Overstrand Heritage Survey (Baumann et al., 2009) considers the landscape character of the coastline between Franskraal and Pearly Beach to be an area of very high significance, with the inland portion of moderate significance (Figure 6). This landscape character derives from the juxtaposition and combination of natural features – mountains and coastline - along scenic corridors, and the location within those corridors and vistas of settlements and villages, pockets of rural farmland and nature and marine reserves.

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Figure 6. Landscape Significance Map; red circle indicates study area (Baumann et al., 2009: 38).

3.3.6. Scenic Route The R43 is recognised in the Overstrand Heritage Survey (Baumann et al., 2009) as a Scenic Route of high, local significance, with a proposed Grade III grading, in recognition of its scenic and natural qualities. While this report has not yet been ratified by Heritage Western Cape, its findings have been supported and are accepted as officially adopted by the Overstrand Municipality.

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Figure 7. All known heritage sites in the immediate vicinity of the proposed project area. All of these are archaeological (See Table 1).

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Figure 8. The locations of the historic Awila werf and the more recent Farm 227 werf relative to the proposed development.

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4. IDENTIFICATION OF HERITAGE RESOURCES 4.1. Summary of Findings of Specialist Reports 4.1.1. Archaeological Impact Assessment Several Later Stone Age sites were identified in the course of the archaeological survey. Predominantly these sites comprised shell middens of varying degrees of intactness. Four well preserved middens (Sites PBAF512, PBAF612, PBAF1012 and PBAF1612), exhibited whole and fragmentary shellfish, including T. Sarmaticus & operculum, Scutellastra tabularis, Cymbula oculus, S. Argenvillei & S. Longicosta and Haliotis sp. In addition to the shellfish remains, these sites variously contained quartzite cobbles, flakes and chunks. Sites PBAF1012 and PBAF1016 also contained hammerstones and upper grindstones. The remaining six less well preserved sites generally comprised only ephemeral and dispersed scatters of shellfish with occasional stone tool occurrences. No bone or ostrich egg shell beads were noted at any of the sites, and indigenous pottery was only recorded at one site (PBAF313). The proposed development area contained no evidence for historical archaeological remains, or structures. There were similarly no graves or burial grounds identified on the site.

The proposed layout will avoid the buffers proposed around the significant sites, and as such, no impacts are anticipated to significant archaeological heritage.

4.1.2. Visual Impact Assessment A Visual Impact Assessment (VIA) was conducted by Oberholzer and Lawson (2019), and those aspects of this report relating to both tangible and intangible heritage resources are considered here, with the primary focus being visual impacts to the Cultural Landscape. The report identified two dwellings that, while falling within the viewshed of the proposed development, are not older than 60 years and are not of heritage significance. The assessment noted the proximity of Pearly Beach, predominantly a holiday town, as well as the township of Eluxolweni, which is immediately adjacent to the development area. The area, with its white sandy beaches, location along the Whale Route, and status as an angling destination, is identified as having high natural landscape and scenic value with tourism significance and importance as a recreational amenit.

The VIA (Oberholzer and Lawson, 2019) noted that the low growing vegetation offers little visual screening, while the rolling dunes provide some moderate screening. The proposed development will be most highly visible from the beach opposite the development area, and from along the R43. From other vantage points, the site will be partially screened by the topography and vegetation.

Mitigatory measures including reducing the height of structures and increasing their setback from the northern and southern extents of the property will serve to reduce impacts from high to medium.

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4.2. Heritage Resources identified 4.2.1. Archaeology Overall, there were no constraints or limitations associated with the study. Infestation of the frontal dune area with alien vegetation, and dense occurrences of natural vegetation along the back dunes did limit mobility and visibility in those areas. The north eastern extent of site adjacent to the R43 was not surveyed due to the dense vegetation cover there and the general lack of archaeological resources found at that distance from shoreline in this region. As such, survey was restricted to the area within approximately 950m from the shoreline.

Stone Age Sites All identified archaeological occurrences were Later Stone Age sites, and were identified by varying quantities of marine shell residues sometimes with associated stone artefacts and a single occurrence of pottery fragments at one site (Figure 10). Eleven sites were identified, ranging in density from well- preserved shell middens with hammerstones, upper grindstones on quartzite and associated other stone artefacts on quartz and quartzite (Figure 9 to Figure 16). Shellfish comprised Turbo sarmaticus, identified at all eleven sites, as well as various limpet species and whelks. Four fragments of thin walled coarse tempered, unburnished, undecorated pot sherds from a single vessel were identified at PBAF313, a low significance site (Figure 10).

Built Environment Some low significance elements of farming infrastructure were identified on the property, but there was no evidence for historic built structures within the development site. The property is a relatively recent subdivision of the historic farm Lang Gelegen, with no historic werf on the property. The historic werf of Farm Awila is over 2.5km from the development area, on the northern side of the R43.

Cemeteries No evidence for cemeteries, individual formal or informal graves or burial cairns was identified on the property.

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Figure 9. PBAF213, outside the development area (Kaplan, 2019). Figure 11. PBAF512, on an east facing slope (Kaplan, 2019).

Figure 10. Thin walled, coarse tempered, unburnished, undecorated pot sherds (from a single vessel) recorded at PBAF313 (Kaplan, 2019).

Figure 12. North facing aspect of PBAF1012 (Kaplan, 2019). 16

Figure 13. West facing aspect of PBAF1012 dune mound (Kaplan, 2019). Figure 15. PBAF1612 on an east facing slope (Kaplan, 2019).

Figure 14. Detail of PBAF1012 on prominent dune mound (Kaplan, 2019). Figure 16. Detail of PBAF1612 (Kaplan, 2019) 17

Table 1. Sites identified in Farm 385 field survey (Kaplan, 2019) Site Description Proposed Mitigation Co- Number grading ordinates PBAF213 Scattered fragments of weathered marine shellfish, including Turbo sarmaticus, Low (IIIC) None required S34° operculum and adiagnostic limpets on a wind eroded cobble bed in the back dune area – 39.582' outside the footprint area. A few quartzite flakes and broken/smashed cobbles. No E19° pottery, OES or bone 28.193' PBAF313 4 fragments of wind blasted, thin walled, coarse tempered, unburnished, undecorated Low (IIIC) None required S34° pot sherds (from a single vessel), and a quartzite cortex flake on a small patch of soft 39.574' white sand. A thin scatter of weathered fragments of shellfish, inc. T. sarmaticus, E19° operculum & a few whelks,in a small footpath, at the bottom of a dune slope a few 28.162' meters away. PBAF413 Scattered fragments of weathered & fragmented shellfish, including T. sarmaticus, Low (IIIC) None required S34° Operculum, and several quartzite cobble flakes and chunks on a shallow dune slope in the 39.590' back dune area, outside the footprint area E19° 28.160' PBAF 512 Relatively well-preserved shell midden deposits occur on a steep, east-facing, vegetated Medium Test excavations S34° dune slope, in the back dune area. Comprising mostly fragmented shellfish (T. Sarmaticus (IIB) and/or sampling of 39.579' & operculum), but also some larger fragments and smaller, whole limpets (Scutellastra deposits to be E19° tabularis), and a few small whelk. Also some burnt shell. Several quartzite flakes & undertaken. 28.146' chunks, but no pottery or OES found Alternatively 10m buffer around the site PBAF 612 Comprises a small patch, of relatively well-preserved shellfish deposits dominated by T. Low (IIIC) – Test excavations S34° sarmaticus, Operculum, and Cymbula oculus and some burnt shell, on a south east facing Medium and/or sampling of 39.583' dune slope in the back dune area, surrounded by dense Rooikrantz. One quartzite cobble (IIB) deposits to be E19° flake and a broken/smashed quartzite cobble. Several small, thin patches of weathered undertaken. 28.123' and fragmented shellfish also occur on the top and side of the dune. No pottery, bone or Alternatively 10m OES buffer around the site PBAF 712 Comprises a thin, dispersed and disturbed/trampled scatter of fragmented shellfish in Low (IIIC) None required S34° small footpath. One large S. argenvillei, and some T. sarmaticus, and Operculum. One 39.580' quartzite chunk E19° 28.107' PBAF 812 Isolated and scattered fragments of fragmented and weathered shellfish and a few Low (IIIC) None required S34° quartzite flakes and chunks, on an expansive bed of wind eroded surface calcrete 39.533' E19°

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28.042' PBAF 912 Dispersed scatter of fragmented and weathered shellfish on an exposed bed of wind Low (IIIC) None required S34° eroded beach cobbles, behind a cobble terrace in the back dune area, surrounded by 39.570' dense alien Rooikrantz. Shellfish comprises mainly T. sarmaticus, but some limpet E19° (including S. argenvillei) also occurs. 1 quartzite flake and one possible quartzite 28.001' hammerstone. No pottery, bone or OES PBAF Well preserved-shell midden deposits recorded on a prominent, very visible dune mound. Medium Test excavations S34° 1012 Shellfish comprises mostly fragmented and weathered shellfish, but larger pieces, and (IIB) and/or sampling of 39.551' some whole shell also occur. Shellfish is dominated by T. sarmaticus, with large and deposits to be E19° smaller Operculum, adiagnostic limpet,but also S. Argenvillei & S. longicosta, small whelk, undertaken. 28.005' large fragments of Perlemoen (Haliotis sp) and periwinkle (D. sinensis). Many unmodified Alternatively 10m quartzite pebbles, large round cobbles, small number of quartzite flakes, inc. 1 buffer around the site hammerstone, 2 misc. upper grindstones, 1 broken, double sided upper grindstone PBAF Well preserved shell midden deposits on exposed, north facing dune slope, about 50m Medium Test excavations S34° 1612 south of Site 1012 in back dune area, surrounded by dense Rooikrantz. Weathered (IIB) and/or sampling of 39.563' shellfish is dominated by T. sarmaticus, Operculum, &adiagnostic limpets. Some burnt deposits to be E19° shellfish also noted. Relatively large number of quartzite flakes, chunks, broken/smashed undertaken. 27.990' cobbles, 1 hammerstone, 3 upper grindstones, 1 misc. grindstone fragment, 1 quartz Alternatively 15m core, and quartz chunks/flakes, many small unworked pebbles. No pottery, bone or OES buffer around the site found.

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4.2.1.1. Mapping of Archaeological Heritage Resources

Figure 17. Map showing area of archaeological survey relative to greater project area. Surveyed area extends c. 950m from the high tide line.

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Figure 18. Trackpaths and sites identified during field survey (Error! Reference source not found.).

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Figure 19. Detail of sites with the recommended buffers indicated around the Grade IIIB sites. Sites PBAF512, 612 and 1012 have recommended buffers of 10m, while PBAF1612 has a recommended buffer or 15m.

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Figure 20. Significant archaeological sites shown with buffers indicated, overlaid on SDP (Gericke, 2019).

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4.2.2. Visual Receptors, Scenic Routes and Cultural Landscapes The sandy beaches and rocky headlands of the immediate area, which are used by holiday makers visiting Pearly Beach, local residents, tourists and anglers, are considered visually sensitive landscape features, with potentially sensitive visual receptors including the settlement of Pearly Beach, surrounding farmsteads, Uilkraalsmond Nature Reserve and users of the R43.

The cultural landscape of the region was deemed to have high local significance as a natural landscape of scenic value, with proximity to important marine reserves and marine life. The VIA notes “[t]he landscape is largely intact except for nearby residential settlements, jeep tracks and sporadic invasive alien vegetation” (Oberholzer and Lawson, 2019: 17).

The facility will be highly visible from the beach near the development site and from the R43, and could potentially be visible from the Uilkraalsmond Nature Reserve. It is unlikely to be visible from Pearly Beach due to the screening effects of the undulating dunes and the vegetation, although lights from the facility might be visible at night. The viewshed analysis showed that while the facility could be visible some distance out to sea, the zone of visual influence would largely be limited on the landward side due to the topography of the area

Figure 21. Dunes and coastal dune thicket at southern extent of the site (Oberholzer and Lawson, 2019: 14).

Figure 22. Existing house to east of development area (Oberholzer and Lawson, 2019: 14).

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Figure 23. View along R43 with an existing power line parallel to the road (Oberholzer and Lawson, 2019: 15).

Table 2. Potential Visibility of proposed development (Oberholzer and Lawson, 2019: 18). View- Location Coordinates Distance Visibility of the project point VP1 Castle Beach access boardwalk 34.666946°S 2.4km Marginally visible 19.496532°E VP2 Charlie van Breda Road, beach lookout 34.664882°S 2.01km Marginally visible 19.492501°E VP3 The beach, opposite the house on the 34.661874°S 502m Moderately visible, partly dunes 19.474315°E screened by dunes VP4 The beach, opposite the site 34.660800°S 70m Highly Visible 19.467145°E VP5 Rotunda Road at western end of 34.659454°S 860m Moderately visible, but mostly Pearly Beach residential area 19.480687° screened by dunes and vegetation. VP6 On ridge near Eluxolweni settlement 34.654411°S 945m Moderately visible, partly 19.484942°E screened by ridges. VP7 Access road near sewage works 34.649674°S 836m Moderately visible 19.494992°E VP8 R43 Route east of the site 34.643769°S 627m Highly visible 19.501490°E VP9 R43 Route west of the site 34.636222°S 661m Highly Visible, partly screened by 19.488332°E vegetation. VP10 R43 route near site boundary 34.638047°S 318m Highly Visible 19.491371°E VP11 Access road on eastern boundary of 34.644689°S 332m Moderately visible the site 19.486696°E

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Table 3. Visual Impact Intensity (severity) of full development phases Visual Criteria Comments Producti Entrance Solar on Area Area PV Facility Visibility of Based on visibility by receptors in the Med- Med-high Low facilities surroundings. high (distance) Visibility of Visibility of 9m poles along eastern boundary Medium Medium Mediu powerlines m Visibility of lights Visibility of security lighting on the perimeter and High Med-high n/a at night at strategic infrastructure. Visual exposure Viewshed extends along beach and out to sea. Medium Medium Low Level (viewshed) Partly restricted to the northeast by dunes. Visual sensitivity Effect on Pearly Beach, nature reserve, Medium Medium Low (features/ surrounding farmsteads. receptors) Effect on beach users, R43 High High Low Landscape Effect on natural coastal and rural landscape High High Low integrity character. (intactness) Visual absorption Visually exposed coastal plain, low undulating Med- Medium Low capacity dunes and low scrub vegetation. high (screening) Visual Impact Summary Medium Medium Low to intensity to high to high mediu m

.

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4.2.2.1. Mapping of Visual Impacts

Figure 24. VIA fieldwork and viewpoints map (Oberholzer and Lawson, 2019: 30).

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Figure 25. Landscape elements near the proposed development with 20m contours depicted (Oberholzer and Lawson, 2019: 31).

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Figure 26. Combined Viewshed Analysis (Oberholzer and Lawson, 2019: 34).

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Figure 27. Viewshed Analysis of entrance area infrastructure (Oberholzer and Lawson, 2019: 32).

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Figure 28. Viewshed Analysis of production area infrastructure (Oberholzer and Lawson, 2019: 32).

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Figure 29. Photomontages of the proposed development from Viewpoints 1 and 2 (Oberholzer and Lawson, 2019: 43).

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Figure 30. Photomontages of the proposed development from Viewpoints 3 and 4 (Oberholzer and Lawson, 2019: 44).

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Figure 31. Photomontages of the proposed development from Viewpoints 5 and 6 (Oberholzer and Lawson, 2019: 45).

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Figure 32. Photomontages of the proposed development from Viewpoints 7 and 8 (Oberholzer and Lawson, 2019: 46).

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Figure 33. Photomontages of the proposed development from Viewpoints 9 and11 (Oberholzer and Lawson, 2019: 47).

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5. ASSESSMENT OF THE IMPACT OF THE DEVELOPMENT 5.1. Assessment of Impact to Archaeological Heritage Resources Impacts to archaeological heritage resources are possible during the construction phase, and residual impacts are likely during operation and decommissioning. Where these sites have been identified as medium significance (Sites PBAF512, PBAF612, PBAF1012 and PBAF1612), potential impacts are medium- high, resulting in a direct, negative impact on archaeological resources through disturbance and destruction of sites during ground clearing and installation of infrastructure. Possible indirect impacts could arise through encroachment on sites and loss of sense of place, as well as environmental degradation that could damage sites, i.e. through dust accumulation, erosion, etc. Additional people on site during the construction phase can also result in a loss of archaeological material through intentional or unintentional damage. Impacts to the low significance sites are not seen as negative.

Some mitigation has been implemented through the amended layout, but it is still possible that impacts to significant archaeology could occur during construction and operation. As impacts remain medium to high, mitigation is required through test excavation of the significant sites and fencing off prior to construction activities taking place on site.

Table 4. Impacts on significant physical archaeological resources Nature: Impacts on physical archaeological sites during the construction of the Pearly Beach Abalone Farm. Without mitigation With mitigation Extent Local (1) Local (1) Duration Permanent (5) Permanent (5) Magnitude Very High (10) Low (4) Probability Definite (5) Improbable (2) Significance High (80) Low (20) Status Negative Negative Reversibility Low Low Irreplaceable loss of resources? Yes, should the sensitive Yes, should the sensitive archaeological sites not be avoided. archaeological sites not be avoided Can impacts be mitigated? Yes Yes Pre-construction test excavation of the significant sites and fencing off of Mitigation: sites PBAF512, PBAF612, PBAF1012 with a 10m buffer, and site PBAF1612 with a 15m buffer. Potential of finding buried archaeological resources or burials during earth Residual impacts: moving.

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5.1.1. Visual Impacts, Including Cultural Landscapes and Scenic Drives Visual impacts to the receiving environment, which can all be considered indirect impacts, will arise as a result of the proposed development, and will occur during the construction, operational and decommissioning phase. These impacts, insofar as they affect heritage resources, pertain to the scarring of the dunes during construction; visual intrusion and clutter caused by the bulk of the development and infrastructure, as well as light pollution during operation; and potential remaining infrastructure after decommissioning. Indirect impacts are possible loss of the natural and scenic qualities of the area and its sense of place, and possible impacts to its recreation amenity value and tourism.

Figure 34. Simulated night view from VP4 on the beach opposite the site (Oberholzer and Lawson, 2019: 48).

The visual impacts of the entrance area and production area infrastructure are similar and are rated as medium to medium-high on a cultural landscape of very high local significance. Mitigatory measures have been recommended pertaining to the planning, construction, operational and decommissioning phases of the proposed development, and will reduce the visual impacts of the abalone farm to medium. The solar facility itself will have only low visual impacts before and after mitigation.

Proposed mitigation includes the implementation of setbacks from the High Water Mark of at least 42m, increasing to 100m for double storey infrastructure. At least a 60m setback is indicated from the R43, while building height should not exceed to 8.5m to eaves, 10m to ridge line. A planted dune should be created along the R43 to shield the development from the R43. A raised dune is also recommended on the southern end of the development to shield views from the beach, but this is not supported due to the impacts it would have on the archaeological sites identified there. Topography should be respected, excavation minimized and no powerlines located on skylines. Redesign of the staff quarters to a more representative ‘rural village’ layout is recommended. Lighting should be unobtrusive, low-level and motion activated where possible, and excessive signage should be avoided. All above ground infrastructure and hard surfaces should be removed during decommissioning and areas should be revegetated.

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Table 5. Visual impacts of proposed development on heritage resources during the construction phase Nature: Negative visual effect of construction activities Abalone Farm Solar PV Plant Without mitigation With mitigation Without mitigation With mitigation Extent Local (2) Local (2) Local (2) Local (2) Duration Short term (2) Short term (2) Short term (2) Short term (2) Magnitude Med-high (8) Moderate (6) Low (2) Low (2) Probability Probable (3) Probable (3) Probable (3) Probable (3) Significance Medium (36) Medium (30) Low (18) Low (18) Status Negative Negative Negative Negative Reversibility Medium Medium Low Low Irreplaceable Medium Medium Medium Medium loss of resources? Can impacts Partially Partially Partially Partially be mitigated? Mitigation: Planning: • Allow appropriate setbacks • Employ screening through increased dune height and vegetation; • Reduce building heights to 8.5m to eaves, 10m to roof line; • Maintain existing topographic ridges and high points and keep these clear of powerlines or solar arrays; • Locate larger structures and PV arrays in low-lying positions; • Supply earthworks plan and avoid excessive earthworks; • Consider redesign of staff houses to allow greater rural village character and align layout to topography; • Employ muted colours on walls and roofs; • Keep access roads narrow and use existing tracks where feasible. Construction: • Locate construction camp and related areas in visually unobtrusive positions, not visible from R43 or beach; • Provide measures to prevent wind-blown sand, dust and litter as part of the EMPr. • Locate pipelines and powerlines underground, where possible. The EMPr to be monitored by an Environmental Control Officer (ECO). Residual Large-scale industrial-type buildings and lights at night in the rural setting. impacts: Powerline on the skyline.

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Table 6. Visual impacts of proposed development on heritage resources during the operational phase Nature: Negative visual intrusion of the project Abalone Farm Solar PV Plant Without mitigation With mitigation Without mitigation With mitigation Extent Local (2) Local (2) Local (2) Local (2) Duration Long term (4) Long term (4) Long term (4) Long term (4) Magnitude Medium-high (8) Moderate (6) Medium-low (3) Medium-low (3) Probability Probable (3) Probable (3) Probable (3) Probable (3) Significance Medium (42) Medium (36) Low (24) Low (24) Status Negative Negative Negative Negative Reversibility Poor Good Poor Good Irreplaceable Medium Medium Medium Medium loss of resources? Can impacts Partially Partially Partially Partially be mitigated? Mitigation: Operations: • Use infrared technology or movement sensors for perimeter security, to minimize the effect of ambient lighting at night on the rural surroundings. • Keep general outdoor lighting as unobtrusive as possible through use of low-level bollard type lights, where needed, such as parking areas and footpaths. • Use discrete external signage and avoid commercial advertising or billboard-type signs. Decommissioning: • On closure of the abalone operation remove all above-ground buildings and structures and recycle building materials. • Rip and regrade all hardened platform areas and access roads that are no longer required. Regrade and revegetate exposed or disturbed areas and return these to natural strandveld to blend with the surroundings. Residual Large-scale industrial-type buildings and lights at night in the rural setting. Powerline on the impacts: skyline.

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Figure 35. Proposed 60m setback line for entrance area infrastructure; 5m contours depicted (Oberholzer and Lawson, 2019: 36).

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Figure 36. Observed setback lines for production area infrastructure; 5m contours depicted (Oberholzer and Lawson, 2019: 38).

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Figure 37.Proposed mitigation measures for production area (Oberholzer and Lawson, 2019: 42).

Figure 38. Proposed mitigation measures for production area (Oberholzer and Lawson, 2019: 41).

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5.2. Cumulative Impacts Cumulative effects can be understood as the combined impacts of a single activity or multiple activities where the individual impacts from a single development become significant when combined with other impacts within the same area, or from the same type of development (Cooper 2004).

As the development design has responded to the location of significant archaeological sites in the landscape, it should not contribute to the cumulative loss of archaeological sites and materials, while mitigation of sites through test excavation offers an opportunity to add to the scientific literature about such sites. The development of further abalone farming facilities, however, pose extensive risks to archaeological material which is concentrated within the very areas preferentially selected for these developments. Further, any development along this coastline will unavoidably contribute to the loss of the wider archaeological landscape. The cumulative effect of future developments is curtailed, however, by the numerous nature and marine reserves in the area that are excluded from development pressures.

Table 7. Cumulative impacts to archaeological heritage resources Nature: Cumulative impacts to archaeological and built environment resources, cemeteries and graves Overall impact of the proposed Cumulative impact of the project and

Project considered in isolation other projects in the area Extent Local (1) Regional (3) Duration Permanent (5) Permanent (5) Magnitude Low (4) High (6) Probability Improbable (2) High (8) Significance Low (20) High (112) Status (positive or negative) Negative Negative Reversibility Low Low Yes, should the sensitive Yes, should the sensitive Irreplaceable loss of resources? archaeological sites not be avoided archaeological sites not be avoided Can impacts be mitigated Yes Yes Confidence in findings High Mitigation: As recommended in Baumann et al. (2009a: 91) developments within a 5-10km area from the coast inland should be limited and not undertaken without an archaeological impact assessment. The recommendations of all assessments should be incorporated into resulting Environmental Management Programmes (EMPs) and the Environmental Authorisations (EAs). Residual Risks: There remains residual risk of the chance discovery of unidentified and/or buried archaeological material or graves. Where these resources are found, the heritage authorities should be notified immediately.

Cumulative visual impacts would potentially occur from the combined development of all the proposed abalone farm phases (6 platform phases over several years), along with the development of the proposed processing plant, storage facilities and solar PV array. Further to this, existing facilities are all located some distance from

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this proposal (13km to Aqunion Romansbaai and 17 to Buffelsjags), or are concentrated in built up areas (Abagold, HIK and Aqunion Hermanus). As abalone farms of this scale have little or no visual effect beyond about 2 to 3 km, it is estimated that the combination of the proposed project with the existing abalone farms would not have any influence on cumulative visual impacts.

This development does serve to expand the perceived urban edge of Pearly Beach, which effectively spreads the developed area further across the as yet undeveloped landscape to the west of the settlement. Such expansion of development and settlement into rural landscapes will serve cumulatively to deplete the scenic qualities and negatively impact the cultural landscape. The location of the development site directly adjacent to Pearly Beach, however, minimises this effect by concentrating development near already altered landscapes. As such, the impact on the rural and scenic cultural landscape is less than would arise from dispersed facilities across the region. It should be noted, however, that the area south of the R43, including the project area, is of scenic rather than heritage value, unlike the farmlands to the north of that road, and as such, impacts to heritage resources are limited. Further, the insertion of agricultural facilities – and particularly marine agricultural facilities – in this landscape is an appropriate, acceptable development type.

Table 8. Cumulative visual impacts to heritage indicators in the region Nature: Cumulative visual impact of proposed Abalone Farm. Overall impact of the proposed Project Cumulative impact of the project and

considered in isolation other projects in the area Extent Local (2) Regional (3) Duration Long term (4) Long term (4) Magnitude Medium-high (8) Medium-high (8) Probability Probable (3) Low (2) Significance Moderate (42) Low (30) Status (positive or Negative Negative negative) Reversibility Poor (1) Poor (1) Irreplaceable loss of Medium Medium resources? Can impacts be mitigated Medium Medium Confidence in findings Moderate Mitigation: Developments that are of moderate visibility or above should be carefully planned to reduce visual impacts and visibility from Scenic Routes and areas of high cultural or scenic significance. Residual Risks: The visual impact will be removed after decommissioning, provided the infrastructure is removed and the landscape successfully rehabilitated and revegetated. Failing this, the visual impact on heritage resources and the rural cultural landscape will remain.

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Figure 39. Map of other abalone farming facilities in the region.

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5.3. Sustainable Social and Economic Benefit HWC considers the sustainable social and economic benefits of a project as contributory to the overall impacts on heritage as a function of living heritage. Potentially negative impacts to heritage need to be considered in the light of proposed developments that will have great socio-economic benefit and carry the capacity to improve people’s welfare. In such instances, it is foreseeable that the value of the project should be considered greater than that of the relevant heritage resources at stake.

A Social Impact Assessment has not been undertaken for this project, but socio-economic benefits including increased employment opportunities, income and skills development, as well as investment in the local and regional economy and infrastructure are likely positive outcomes, with restrictions in access to areas occupied by the facility likely negatives (Barbour, 2007; Massie et al., 2018)

5.4. Proposed Development Alternatives Two alternative layouts were considered, with several refinements being made following specialist input, both from the archaeologist and visual specialist. As such, only the preferred alternative is being proposed, although further refinements should be considered based on the outcomes of the VIA.

A no-go alternative, where no abalone facility was constructed, would entail no impacts to heritage resources, but this alternative would also carry no socio-economic benefits. Although no Social Impact Assessment has been undertaken, the facility will provide economic opportunities at all stages of its development.

6. RESULTS OF PUBLIC CONSULTATION In compliance with the stipulations regarding public participation in Section (2)(4)(f) and (o) of the National Environmental Management Act (NEMA) (Act 14 of 2009) and Section 38(3)(d) of the NHRA (Act 25 of 1999), public consultation was undertaken as part of the EIA Phase of the project (see Appendix 3). This Integrated HIA was provided for comment to the Overstrand Municipality, and the Heritage Conservation Bodies registered for this area, including but not limited to the Overstrand Heritage and Aesthetics Committee and Whale Coast Conservation. Site notices were erected on site informing the public of the availability of the HIA, and it was be advertised in a local newspaper.

Interim comments received from Heritage Western Cape are presented and addressed below; updates to the recommendations of the report were also made based on the outcomes of this consultation.

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Heritage Western Cape APM Committee requested that the northern portion of the site not surveyed as part of the AIA be surveyed. This was undertaken on 30 July 2019 by the HIA author. The northern portion of site is under extensive indigenous vegetation and has several impenetrable stands of wattle. Fires in January 2019 burnt out much of the wattle, however, making access slightly easier in certain places and improving visibility. The ground is sandy and loose, with expanses of calcrete; porcupine burrows and mole hills exposed the substrate in several places. The land is flat and featureless, rising to a ridge of dunes towards the southern extent of the surveyed area. No archaeological finds were identified during the course of the survey. Although the presence of subsurface material cannot be discounted, none was identified on inspection of any of the burrows and mole hills. This absence of material was expected in terms of the known distribution of sites in the region.

Figure 40. View of project area with all trackpaths indicated.

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Figure 41. Aerial image of northern area with survey paths indicated

Figure 42. Trackpaths overlaid on Site Development Plan.

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Heritage Western Cape further highlighted the possibility of the intake and effluent pipes from the proposed facility impacting shipwrecks in the vicinity, and requested that the SAHRA Maritime Unit be offered an opportunity to provide comment on the application.

There are sixteen known shipwrecks in the area, although only ten of these have been located and mapped. The closest mapped shipwreck to the pipes proposed for this facility is some 2.2km away (Figure 43 and Figure 44). The pipes themselves will extend not more than 300m from site in the case of the effluent pipes, and not more than 400m for the intake pipes; there will be three intake pipes and two effluent pipes. The alignment for the pipes will be determined based on the outcome of the engineers’ dive survey, presenting an opportunity to ensure that the pipe alignments do not impact any seabed wrecks.

Table 9. List of mapped and unmapped shipwrecks near Pearly Beach (SAHRA, 2019). Wreck Build Vessel Date Ship Name Area Material Category Vessel Type Mapped Jimmy Le 1838/04/28 Roux Dyer's Island Motor Vessel Yes 5/22/1990 An-Hung 1 Hangklip Motor Vessel Trawler Yes 1877/08/24 Charmer Dyer's Island Wood Sailing Vessel Full-Rigged Yes 1879/04/03 Clyde Dyer's Island Iron Steamship Troopship Yes 1831/05/13 George Dyer's Island Wood Sailing Vessel Cutter Yes 3/23/1913 Hektor Dyer's Island Steel Steamship Yes Cargo Ship 1885/10/11 Imerina Dyer's Island Iron Steamship (Coaster) Yes 1883/05/11 Kolstrop Dyer's Island Wood Sailing Vessel Brigantine Yes 1834/01/16 Linnaeus Dyer's Island Wood Sailing Vessel Barque Yes 1885/03/19 Princeport Dyer's Island Wood Sailing Vessel Ship Yes Unknown - 07 Pearly Beach Iron Unknown No 1888/05/21 Adele Dyer's Island Sailing Vessel Schooner No 1877/02/03 Emelia Dyer's Island Sailing Vessel Schooner No Uilenkraal 1857/05/08 Peacock River Sailing Vessel Cutter No 1877/11/05 Piccadilly Quoin Point Wood Sailing Vessel Brig No 1872/06/18 Telegraph Hangklip Wood Sailing Vessel Schooner No

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Figure 43. Map of known wrecks, indicated within 1km of known locations.

Figure 44. Detail of effluent and intake pipes relative to closest known shipwrecks.

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7. CONCLUSION AND RECOMMENDATIONS 7.1. Conclusion The proposed construction of the Pearly Beach Abalone Farm will likely result in local economic growth, job creation and skills transfer. The archaeological assessment has shown that the coastal region of the proposed development site contains, as expected, several archaeological heritage sites, in the form of shell middens of varying densities, and ephemeral shell scatters. While none of these is of very high significance, the better preserved middens (Sites PBAF512, PBAF612, PBAF1012 and PBAF1612), which contain varied stone artefacts and well preserved shellfish remains are of medium significance and warrant protection. This protection has been partially afforded them by the redesign of the proposed layout. All infrastructure is now planned to avoid the sites and respect their buffers. However, as residual risks to these sites remains medium to high, it is proposed that test excavation of each of the four sites is undertaken under a workplan to assess the depth and significance of the deposit. The sites should also be fenced off, with the fencing undertaken under monitoring by an archaeologist.

The greatest impact will be to the scenic natural and rural cultural landscape, and this impact will be medium to high without mitigation. In this instance, mitigation is possible, but will serve only to reduce the impact to medium. It should be noted, however, that the qualities of the landscape south of the R43 are scenic, unlike the farmlands to the north of the road; as such, impact to heritage resources are limited.

Cumulative impacts arising from further development of abalone farming facilities in the region will have impacts on the wider cultural landscape and the scenic qualities of the area, despite the facilities not being visible over more than 2-3kms. Impacts will also result to the extensive archaeological material which is located along the coastline in the areas most suitable for the development of such facilities. As such, there should be an upper limit placed on the number of these facilities that can be built, as well as forward planning by the Overstrand Municipality regarding their location and distribution. Concentration of facilities in and around developed areas should be encouraged as far as possible in order to retain the unspoilt vistas the area is known for. This facility is located adjacent to a developed area, Pearly Beach, and has undergone layout revisions to limit its impacts to archaeological resources.

It is the opinion of this specialist that, provided the recommendations below are implemented and incorporated into the EMPr, Environmental Authorisation for this project should be awarded.

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7.2. Recommendations The following recommendations were made in terms of impacts to the archaeological heritage resources:

• Test excavations/sampling of deposits must be undertaken at PBAF512 (S34°39.579' E19°28.146') prior to construction activities commencing. Alternatively, a buffer of 10m must be established around the site. • Test excavations/sampling of deposits must be conducted at PBAF612 (S34°39.583' E19°28.123') prior to construction activities commencing. Alternatively, a buffer of 10m must be established around the site. • PBAF1012 (S34°39.551' E19°28.005') must be sampled prior to construction activities commending. Alternatively, a buffer of 10m must be established around the site. • PBAF1612 (S34°39.563' E19°27.990') must be sampled prior to construction activities commending. Alternatively, a buffer of 15m must be established around the site.

The following recommendations are made in terms of impacts to the archaeological heritage resources, considering the residual threat posed by the proximity of the facility to the significant sites:

• The sites listed above, PBAF512 (S34°39.579' E19°28.146'), PBAF612 (S34°39.583' E19°28.123'), PBAF1012 (S34°39.551' E19°28.005'), PBAF1612 (S34°39.563' E19°27.990'), must be subject to test excavation prior to development. A qualified archaeologist must supervise the erection of protective fencing once sampling has been undertaken. All fences should observe the recommended buffers for each site (10m for PBAF512, PBAF612 and PBAF1012, 15m for PBAF1612) and no development activities should occur within those buffers. • Vegetation clearing operations, particularly in the coastal foredunes, must be monitored by a professional archaeologist. If any archaeological deposits are exposed, these might need to shovel tested under a Work Plan permit, to determine the potential significance of the deposits. • Bulk earthworks (e. g. for water, electricity, sewerage, &intake & discharge pipelines) must be monitored by a professional archaeologist. This can be done in consultation with the Environmental Control Officer (ECO) who must be on site during the Construction Phase of the project. The archaeologist does not need to be on site permanently, but should visit the site at least once a week during the Construction Phase, or when the need arises. If any archaeological deposits are exposed during these activities, these may need to be sampled or excavated to determine the significance of the deposits. • Excavations for building foundations (e. g. proposed managers house, administration offices, intake

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& effluent area) must be monitored by a professional archaeologist. If any archaeological deposits are exposed during these activities, these may need to be sampled or excavated to determine the significance of the deposits. • If any unmarked Khoesan graves are uncovered or exposed during bulk earthworks and excavations, these must immediately be reported to the contracted archaeologist or Heritage Western Cape (Att: Mr Andrew September 021 483 9685). In the case of human burials, these will have to be removed under a permit issued by HWC. • The above recommendations must form part of the Construction Environmental Management Plan (EMP) for the proposed development.

The following recommendations are made in terms of visual impacts to the cultural landscape and scenic routes:

Planning and Design Mitigation Measures • Maintain a 42m minimum setback from the high water mark (HWM) for all structures, including paddle ponds, pump house, electrical rooms, parking and fencing, to provide adequate space for coastal dunes and screening of large scale structures when viewed from the beach. (Fig. 8). • Maintain a 100m minimum setback from the HWM for all other development, to minimize visibility of proposed 2-storey structures from the beach, and for coastal legislation purposes. • Maintain a 60m minimum visual setback from the R43 property boundary to minimize visibility of the proposed development from the scenic / tourist route, (Fig. 7). • Reduce the height of the feed manufacture and storage building (Building 'D') from 12m to 8.5m. • Restrict the height of all buildings in the proposed development to 8.5m (eaves height) and 10.0m (top of gable, or roof line), measured from natural ground level. • Construct a planted dune along the R43 boundary with a minimum height of 7.0m above road level. Spoil material from the earthworks for the development could be used. • Except for gate posts at the entrance, no solid walls on the R43 to be permitted. Only see-through type fencing to be used, in order to retain the rural character of the area. • Avoid locating powerlines on the crests of dunes or on high ground, where they will be visible on the skyline. • Fit all security and perimeter lighting with sensors so that these are only activated by movement, to minimize the visual impact of lighting at night on the rural surroundings. • Maintain existing topographic ridges and high points, where possible to maintain the visual integrity of the skyline seen from surrounding areas.

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• Locate large structures in low-lying positions of the site, where possible, and minimize earthworks and disturbance to the site by taking the topography into account. Consider locating Platforms 3A and 3B further north to avoid high ground and excessive earthworks. • Provide an earthworks plan, indicating levels of buildings, platforms and roads, and all cut and fill slopes, including embankment gradients. The earthworks plan to be submitted as part of the Basic Assessment submission. • Consider grouping the proposed staff houses around a werf or courtyard, to create a more rural village character, instead of the current 'township' layout. Consider locating the housing complex in a NW-SE direction in keeping with the topography. • Locate the solar PV arrays in a low-lying area, off any dune ridges, and in sympathy with the topography. • Reduce the visibility of proposed seafarm buildings by using muted colours for wall and roofs. • Screen buildings and infrastructure with planted earth berms (artificial dunes), where possible. • Keep access roads as narrow as possible, as currently proposed, and use existing tracks where appropriate.

A recommendation to Increase the height of the frontal dunes to a minimum of 6.5m above MSL and stabilize the dunes with suitable planting to provide visual screening and coastal protection is not supported in terms of the irreparable damage such an action would have on the archaeological material located in that frontal dune area.

Construction Mitigation Measures • Locate the construction camp and related storage/stockpile areas in visually unobtrusive positions on the site, where these are not visible from the beach or R43. • Provide measures to prevent wind-blown sand, dust and litter as part of the EMPr. • Locate pipelines and powerlines underground, where possible. • The EMPr to be monitored by an Environmental Control Officer (ECO).

Operation / Lighting Mitigation Measures • Use infrared technology or movement sensors for perimeter security, to minimize the effect of ambient lighting at night on the rural surroundings. • Keep general outdoor lighting as unobtrusive as possible through use of low-level bollard type lights, where needed, such as parking areas and footpaths. • Use discrete external signage and avoid commercial advertising or billboard-type signs. Fix signs to

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buildings or walls, if possible, to avoid the visual clutter of signposts.

Decommissioning Mitigation Measures • On closure of the abalone operation remove all above-ground buildings and structures and recycle building materials. • Rip and regrade all hardened platform areas and access roads that are no longer required. • Regrade and revegetate exposed or disturbed areas and return these to natural strandveld to blend with the surroundings. (Revegetation measures to be prescribed by the vegetation/ biodiversity specialist).

Monitoring Recommendations • Construction Phase Monitoring: Ensure that visual mitigation measures are included as part of the EMPr, monitored by an ECO, including the siting of the construction camp and stockpiles, dust suppression and litter control measures, with regular reporting to an environmental management team.

• Operation Phase Monitoring: Ensure that visual mitigation measures are monitored by management on an on-going basis, including the control of signage, lighting and wastes on the site, with interim inspections by a delegated ECO.

• Decommissioning Phase Monitoring: Ensure that procedures for the removal of structures and stockpiles during decommissioning are implemented, including recycling of materials and rehabilitation of the site to a visually acceptable standard as prescribed in a rehabilitation plan, and signed off by the delegated authority.

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8. REFERENCES Avery, G. 1976. A systematic investigation of open station shell midden sites along the southwestern Cape coast. Unpublished MA thesis: University of . Barbour T. 2007. Guideline for involving social assessment specialists in EIA processes. Prepared for Department of Environmental Affairs and Development Planning, Western . Baumann, N., Attwell, M., Clift, H., Deacon, H., Jacobs, G., Oberholzer, B. And Winter, S. 2009a. Draft Overstrand Heritage Survey. Unpublished report prepared for the Overstrand Municipality. Baumann, N., Attwell, M., Clift, H., Deacon, H., Jacobs, G., Oberholzer, B. And Winter, S. 2009b. Public Participation Document: Bredasdorp Farms. Unpublished report prepared for the Overstrand Municipality. Grine, F.E., 2000. Middle Stone Age human fossils from Klipgat Cave 1, Western Cape Province, South Africa. Journal of Human Evolution 38:129-145. Hall, M. 1984. The Late Stone Age in the area: a distributional study. Part I: Final report to the Human Sciences Research Council. Spatial Archaeology Research Unit, Department of Archaeology, University of Cape Town, Cape Town Hart, T. 2006. Phase 1 Heritage Assessment of a proposed development of farm 227 Pearly Beach, South Western Cape. Unpublished report for Pierre Joubert, Landscape Architect and Environmental Consultant. Cape Town: Archaeology Contracts Office. Hart, T. and Halkett, D. 2012. Environmental Impact Assessment for the Proposed Nuclear Power Station (‘Nuclear 1’) and Associated Infrastructure Heritage Impact Assessment. Unpublished report. Cape Town: Archaeology Contracts Office. Kaplan, J. November 2003. Phase 1 Archaeological Impact Assessment: Proposed wastewater Treatment Works, Pearly Beach. Second Draft for Comments. Unpublished report for SRK Consulting Engineers and Scientists. Cape Town: ACRM. Kaplan, J. 2019. A Baseline Archaeological Study: Proposed Abalone Farm on Erf 385, Pearly Beach Western Cape. Unpublished report. Rondebosch: ACRM. Marean, C.W., 2000. The Middle Stone Age at Klipgat Cave 1, South Africa. Journal of Human Evolution 38:3- 5. Massie, V. Hutchings. K. and Clark, B. 2018. Proposed Abalone Holding and Processing Facility for Port Nolloth Sea Farms Ranching (Pty) Ltd Kleinzee, Northern Cape – Draft Basic Assessment Report: Appendix F: Environmental Impact Assessment. Unpublished report for Port Nolloth Sea Farms Ranching (Pty) Ltd. Tokai: Anchor Environmental. Mucina, L. & Rutherford, M.C. (Eds). 2006. The vegetation of South Africa, Lesotho and Swaziland. Pretoria: SANBI. Rutherford, M.C., Mucina, L. &Powrie, L.W. 2006. Biomes and bioregions of Southern Africa. In: Mucina, L. &Rutherford, M.C. (eds), The vegetation of South Africa, Lesotho and Swaziland. Pretoria: SANBI. Pp.

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30-51. South African Heritage Resources Information System (SAHRIS) 2014. SAHRIS PalaeoSensitivity Map [image]. Available at:http://www.sahra.org.za/sahris/map/palaeo [Accessed on 18 June 2018]. United Nations Educational, Scientific and Cultural Organisation (UNESCO) 2017. Operational Guidelines for the Implementation of the World Heritage Convention [online].Available at: http://whc.unesco.org/en/guidelines [Accessed on 25 June 2018]. Webley, L. 2014. Heritage Impact Assessment Consisting of an Archaeological Study: Construction of a Waste Water Treatment Works at Pearly Beach on Erf 2046, 1896 and Portion 4 of Farm 321, Overstrand. Unpublished report. Cape Town: ACO Associates. Webley., L. and Hart, T. 2012. Heritage Impact Assessment of Nine Proposed Borrow Pit Developments for the Gansbaai-Bredasdorp Road Upgrade Project, Western Cape. Unpublished report. Cape Town: ACO Associates. Winter, S and Oberholzer, B. 2013. Heritage and Scenic Resources: Inventory and Policy Framework. Provincial Government of the Western Cape: Department of Environmental Affairs and Development Planning.

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9. APPENDICES Appendix 1. Table of Proposed Abalone Facilities

Production Facility Footprint Height Comments Development footprint 24.72 ha - 1000 tons, developed in 6 phases of 160 tons each. Platform 1A and 1B 34 560 m2 800mm 2 548 canvas grow tanks, 4m x 1.9m Platform 2A and 2B 34 560 m2 800mm 2 548 canvas grow tanks, 4m x 1.9m Platform 3A and 3B 34 560 m2 800mm 2 548 canvas grow tanks, 4m x 1.9m Manager's House 300 m2 8m Double storey, off-white plastered, green 30º pitch roof, height to top of gable Pump House 1 080 m2 4m Flat roof concrete structure Office Building 560 m2 9m Double storey, off-white plastered, green 30º pitch roof, height to top of gable Paddle Ponds 3 000 m2 1.5m Concrete block structure Hatchery 5 000 m2 5 & 8m Single/Double storey, Grey steel clad portal frame building Training and Office (x2) 150 m2 x2 7m Double storey, off-white plastered, green 30º pitch roof, height to top of gable Header Tanks (x3) 450 m2 x3 8.5 m Flat roof concrete structure, rooftop balustrade Security Camera Structure (x3 on 300 x 300 x 6m Triangular lattice structure 300mm LiveHeader Export Tanks) and Packing (x3) 1 568 m2 x3 8m Double storey, Insulated panel clad portal frame building Electrical Room (x4) 36 m2 x4 3.2m Off-white plastered, green 30º pitch roof, height to top of gable Multiuse Platform Building 1 (x3) 380 m2 x3 8.5m Double storey, off-white plastered, green 30º pitch roof, height to top of gable Multiuse Platform Building 2 (x3) 520 m2 x3 8.5m Double storey, off-white plastered, green 30º pitch roof, height to top of gable Processing / Cannery 1 225 m2 8m Single storey, Insulated panel clad portal frame building Security and Biosecurity 150 m2 Off-white plastered, green 30º pitch roof, height to top of gable Generator Room 100 m2 4.5m Off-white plastered, green 30º pitch roof, height to top of gable Access roads Parking 28 546 m2 n/a 6.5m wide gravel access roads and parking Eskom Power Line 3.5km 9m Standard 3 phase Eskom powerline Perimeter Fencing 2km 2.5m 2m Green ClearVue Fencing with electric fencing Lighting - 6m Solarover street light poles, 50m spacing along all Infrastructure at R43 Entrance Footprint Height roadsComments and perimeter fencing Development footprint 5.95 ha - - Open storage area 500 m2 2.5m Green ClearVue Fencing

Eskom Transformer and Generator 100 m2 4.5m Off-white plastered, green 30º pitch roof, height to top of gable Guard Hut 50 m2 3.2m Off-white plastered, green 30º pitch roof, height to top of gable Feed Manufacture and Storage 1 200 m2 12m Double storey. Grey steel-clad portal frame building Store and Receiving 600 m2 8.5m Double storey. Grey steel-clad portal frame building Workshop 400 m2 8.5m Double storey. Grey steel-clad portal frame building Guards and Security 100 m2 4.5m Off-white plastered, green 30º pitch roof, height to top of gable Parking Security 100 m2 - Paved parking area

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Clinic 100 m2 5m Off-white plastered, green 30º pitch roof, height to top of gable Creche Play Area 200 m2 - Grassed play area, Green ClearVue Fencing Creche 200 m2 5.5m Off-white plastered, green 30º pitch roof, height to top of gable Children Play Area and Sports 1 000 m2 - Grassed play area, Green ClearVue Fencing PackageField Plant 100 m2 - Ground Level Housing Units x24 225 m2 erven 4.5m Off-white plastered, green 30º pitch roof, height to top of gable Entrance Area roads 478 460 m2 mhouses2 n/a 6.5m wide tar roads and parking Access Roads 3 277 m2 n/a 6.5m wide gravel access road to Production Area Perimeter Fencing 1 275 m2 2.5m 2m Green ClearVue Fencing with electric fencing Lighting - 6m Solarover street light poles, 50m spacing along all

Solar Array 20 000 m2 1m Solarroads Panel and perimeter Array fencing

Appendix 2. Table of known heritage resources within the vicinity of the project area (SAHRIS, 2019).

SAHRIS Proposed Site No. Site Name Site Type ID Grading Latitude Longitude Artefacts, Shell 19266 PEARLY1 Pearly Beach 1 Midden Grade IIIc -34.670158 19.511382 Artefacts, Shell 19267 PEARLY2 Pearly Beach 2 Midden Grade IIIc -34.669951 19.510558 Artefacts, Shell 19268 PEARLY3 Pearly Beach 3 Midden Grade IIIc -34.668456 19.511584 Pearly Beach erf 332 19269 PEARLY332-1 - 1 Shell Midden Grade IIIc -34.663283 19.491183 Pearly Beach erf 332 19270 PEARLY332-2 - 2 Shell Midden Grade IIIc -34.663217 19.49155 Pearly Beach erf 332 Artefacts, Shell 19271 PEARLY332-3 - 3 Midden Grade IIIc -34.663367 19.49175 Pearly Beach erf 332 Artefacts, Shell 19272 PEARLY332-4 - 4 Midden Grade IIIc -34.663617 19.49235

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Appendix 3. a. HWC Response to NID 10 October 2018

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b. HWC Interim Comment 11 September 2019

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c. Site Notices

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a. Proof of Consultation

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Appendix 4. AIA

Appendix 5. VIA

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