Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province
Heritage Impact Assessment
Project Number: LEA5514
Prepared for: Limpopo Economic Development Agency
July 2019
______Digby Wells and Associates (South Africa) (Pty) Ltd Co. Reg. No. 2010/008577/07. Turnberry Office Park, 48 Grosvenor Road, Bryanston, 2191. Private Bag X10046, Randburg, 2125, South Africa Tel: +27 11 789 9495, Fax: +27 11 069 6801, [email protected], www.digbywells.com ______Directors: GE Trusler (C.E.O), LF Stevens, J Leaver (Chairman)*, NA Mehlomakulu*, DJ Otto *Non-Executive ______
This document has been prepared by Digby Wells Environmental.
Report Type: Heritage Impact Assessment
Environmental Authorisation for the proposed Musina- Project Name: Makhado Special Economic Zone Development Project, Limpopo Province
Project Code: LEA5514
Name Responsibility Signature Date
Shannon Hardwick
Junior Heritage Resources HIA Compilation Management Consultant
ASAPA Member: 451
July 2019
Justin du Piesanie
Divisional Manager: Social and Technical Review Heritage Services ASAPA Member 270
This report is provided solely for the purposes set out in it and may not, in whole or in part, be used for any other purpose without Digby Wells Environmental prior written consent.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
DECLARATION OF INDEPENDENCE
Digby Wells and Associates (South Africa) (Pty) Ltd
Contact Person: Shannon Hardwick
Digby Wells House Tel: 011 789 9495 48 Grosvenor Road Fax: 011 789 9498 Turnberry Office Park, Bryanston E-mail: [email protected] 2191
I, Shannon Hardwick as duly authorised representative of Digby Wells and Associates (South Africa) (Pty) Ltd., hereby confirm my independence (as well as that of Digby Wells and Associates (South Africa) (Pty) Ltd.) and declare that neither I nor Digby Wells and Associates (South Africa) (Pty) Ltd. have any interest, be it business, financial, personal or other, in any proposed activity, application or appeal in respect of the Limpopo Economic Development Agency, other than fair remuneration for work performed, specifically in connection with the Heritage Resources Management (HRM) Process for the proposed Musina-Makhado Special Economic Development Zone Development Project, Limpopo Province.
Full Name: Shannon Hardwick
Title/ Position: Heritage Resources Management Consultant
Qualification(s): MSc
Experience (Years): 2 years
Registration(s): Association of Southern African Professional Archaeologists (ASAPA)
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
DECLARATION OF INDEPENDENCE
Digby Wells and Associates (South Africa) (Pty) Ltd
Contact Person: Justin du Piesanie
Digby Wells House Tel: 011 789 9495 48 Grosvenor Road Fax: 011 789 9498 Turnberry Office Park, Bryanston E-mail: [email protected] 2191
I, Justin du Piesanie as duly authorised representative of Digby Wells and Associates (South Africa) (Pty) Ltd., hereby confirm my independence (as well as that of Digby Wells and Associates (South Africa) (Pty) Ltd.) and declare that neither I nor Digby Wells and Associates (South Africa) (Pty) Ltd. have any interest, be it business, financial, personal or other, in any proposed activity, application or appeal in respect of the Limpopo Economic Development Agency, other than fair remuneration for work performed, specifically in connection with the Heritage Resources Management (HRM) Process for the proposed Musina-Makhado Special Economic Development Zone Development Project, Limpopo Province.
Full Name: Justin du Piesanie
Title/ Position: Divisional Manager: Social and Heritage Services
Qualification(s): MSc
Experience (Years): 12 years
Association of Southern African Professional Archaeologists (ASAPA) Registration(s): International Council on Monuments and Sites (ICOMOS) South Africa International Association for Impact Assessment South Africa (IAIAsa)
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
EXECUTIVE SUMMARY
The Limpopo Economic Development Agency (LEDA) is proposing to develop a Special Economic Zone (SEZ) which spans across parts of both the Musina and Makhdo Local Municipalities of the Limpopo Province (“the Project”). The Project is adjacent to the National Route 1 (“N1) highway and includes eleven plants and ancillary infrastructure associated with the metallurgical and mineral beneficiation value chain. The Project requires Environmental Authorisation (EA) through an Environmental Impact Assessment (EIA) process, to comply with the National Environmental Management Act, 1999 (Act No. 107 of 1998) (NEMA). To this end, LEDA appointed Delta Built Environment Consultants (Pty) Ltd (hereinafter Delta BEC) to undertake the required EIA process. LEDA subsequently advertised tenders for other consultancies to undertake specialist studies in support of the EIA process. LEDA appointed Digby Wells Environmental (hereinafter Digby Wells) to undertake the Heritage Resources Management (HRM) process, inclusive of a Palaeontological Impact Assessment (PIA) (refer to Appendix C). Digby Wells undertook the HRM process in compliance with Section 38 of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA). This report constitutes the Heritage Impact Assessment (HIA) report for submission to the South African Heritage Resources Agency (SAHRA) and the Limpopo Heritage Resources Authority (LIHRA). Through an understanding of various heritage resources distribution within the site-specific study area, the statement of Cultural Significance (CS) demonstrates an average low significance rating for the defined cultural landscape. This is summarised in the table below. The infrastructure design and site layout has not been finalised at the time of assessment and will be, in part, informed by the outcomes of this assessment. It is therefore anticipated that all heritage resources will be affected by the Project. The final table below presents a summary of the impact assessment. The preceding table presents an overview of the potential risks to unidentified heritage resources within the Project area. To mitigate against the identified impacts against cultural and fossil heritage resources, Digby Wells recommends:
■ LEDA amends the infrastructure design where possible to avoid identified heritage resources of significance within the Project area and incorporate a no-go buffer zone of 50 m between the heritage resources and Project activities. Digby Wells acknowledges that it may not be feasible to avoid all the identified heritage resources;
■ Where identified heritage resources are avoided, LEDA must develop and implement a Conservation Management Plan (CMP) to manage conserved heritage resource. The CMP must include any applicable mitigation measures, management strategies and proposed monitoring schedules and outline the roles and responsibilities of those involved. This document must be submitted to the Heritage Resource Authorities (HRAs) for approval prior to implementation;
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
■ LEDA amends the Project design to avoid negative impacts to the built heritage resources and, where possible, conserve the resources through adaptive reuse of the structures. This will require a permit issued in terms of Section 34 of the NHRA and Chapter III of the NHRA Regulations, 2000 (Government Notice Regulation [GN R] 548);
■ Where adaptive reuse of the structures is not feasible or desirable, LEDA must complete a destruction permit application process in accordance with Section 34 of the NHRA and Chapter III of the NHRA Regulations;
■ Where burial grounds and graves will be impacted upon by the proposed infrastructure, LEDA must undertake a GRP in accordance with Section 36 of the NHRA and Chapter IX and XI of the NHRA Regulations;
■ Where archaeological sites will be impacted upon by the proposed infrastructure, LEDA must record the sites in detail in accordance with Section 35 of the NHRA and Chapter IV of the NHRA Regulations;
■ A Project-specific Chance Finds Protocol (CFP) must be developed and approved by the HRAs prior to the commencement of the construction of Project-related infrastructure; and
■ The Project-specific Fossil Finds Protocol (FFP) must be approved prior to the commencement of the construction phase of the Project (refer to Appendix A of the PIA report).
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Summary of the CS of Identified Heritage Resources
Resource ID Description CS
INTEGRITY
Geological strata with Lithologies of the Karoo Supergroup 4 Very High palaeontological sensitivity
STE-002 Historical structure 3 Low
STE-001 Historical structures 1 Negligible
SA-001 Isolated archaeological artefact 1 Negligible
Summary of the potential risk to heritage resources
Mitigation / Management / Unplanned event Potential impact Monitoring
Accidental damage to in situ Damage or destruction of historical built environment sites heritage resources generally during the implementation of the protected under Section 34 of
Project. the NHRA.
Accidental exposure of fossil bearing material implementation of the Project. Damage or destruction of heritage resources generally Accidental exposure of in situ protected under Section 35 of Establish Project-specific CFPs archaeological material during the NHRA. and FFPs as a condition of the implementation of the authorisation. Project.
Accidental exposure of in situ burial grounds or graves during the implementation of the Damage or destruction of Project. heritage resources generally protected under Section 36 of Accidental exposure of human the NHRA. remains during the construction phase of the Project.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Mitigation / Management / Unplanned event Potential impact Monitoring
Accidental damage to in situ Damage or destruction of Establish Project-specific CFPs historical built environment sites heritage resources generally and FFPs as a condition of during the implementation of the protected under Section 34 of authorisation. Project. the NHRA.
Should sites be identified within the Project area, such sites must be included in the CMP.
Increased dust generated by Upon identification, immediate Negative changes to the status Project activities during the remedial action includes: quo and integrity of heritage construction and operational resources, specifically Rock Art, ■ Recording the Rock Art phase of the Project that could generally protected under sites baseline conditions; impact on previously Section 35 of the NHRA and unidentified heritage resources. ■ Include identified sites into a monitoring programme encapsulated in the CMP
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Summary of the Impact Assessment
Duration Extent Intensity Consequence Probability Significance Impact Pre-mitigation:
Extremely high - Extremely Direct impact to BGG Permanent International Highly probable Major - negative negative detrimental
Direct impact to Moderately Moderate - Historical Structure of Permanent Province/ Region Very low - negative Highly probable detrimental negative Low CS
Impact Post-mitigation:
Moderately Moderate - Direct impact to BGG Beyond project life Local High - positive Highly probable beneficial positive Direct impact to Historical Structure of Beyond project life Limited Very low - positive Slightly beneficial Highly probable Minor - positive Low CS
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
TABLE OF CONTENTS
1 Introduction ...... 12
1.1 Project Background and Description ...... 12 1.2 Project Alternatives ...... 13 1.3 Terms of Reference ...... 14 1.4 Scope of Work ...... 14 1.5 Expertise of the Specialist ...... 17 1.6 Structure of the Report ...... 18 2 Legislative and Policy Framework ...... 20
3 Constraints and Limitations ...... 24
4 Methodology ...... 26
4.1 Defining the Study Area ...... 26 4.2 Statement of Cultural Significance ...... 27 4.3 Definition of Heritage Impacts ...... 27 4.4 Secondary Data Collection ...... 28 4.5 Primary Data Collection ...... 30 4.6 Site Naming Convention ...... 30 5 Cultural Heritage Baseline Description ...... 31
5.1 Existing Environment ...... 38 5.2 Results from the pre-disturbance survey ...... 38 6 Impact Assessment ...... 42
6.1 Cultural Significance of the Identified Landscape ...... 42 6.2 Heritage Impact Assessment ...... 45 6.2.1 Direct impacts to Burial Grounds and Graves ...... 45 6.3 Cumulative impacts on the cultural landscape ...... 47 6.4 Low risks and unplanned events ...... 48 7 Identified Heritage Impacts versus Socio-Economic Benefit ...... 49
8 Consultation ...... 52
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
9 Recommendations ...... 52
10 Conclusion...... 53
11 Works Cited ...... 55
LIST OF FIGURES
Figure 5-1: Heritage resources identified within the greater study area ...... 32 Figure 5-2: Current Environment at the time of the pre-disturbance survey ...... 37 Figure 5-3: Photographs of heritage resources identified during the pre-disturbance survey. A.) SA-001, B.) and C.) two sides of STE-002; D.) BGG-001, E.) STE-001 and F.) BGG-002 ...... 40 Figure 7-1: Employment status within the regional study area ...... 51
LIST OF PLANS
Plan 1: Regional Setting of the Project ...... 15 Plan 2: Project area indicating the various properties ...... 16 Plan 3: Previously-identified heritage resources within the Regional Study Area ...... 33 Plan 4: Results from the Pre-disturbance Survey ...... 41
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
LIST OF TABLES
Table 1-1: Expertise of the specialists ...... 17 Table 1-2: Structure of the report ...... 18 Table 2-1: Applicable Legislation Considered in the HRM Process ...... 20 Table 2-2: Applicable policies considered in the HRM process ...... 24 Table 3-1: Constraints and Limitations ...... 24 Table 4-1: Impact Definition ...... 27 Table 4-2: Qualitative Data Sources ...... 28 Table 4-3: Aerial imagery considered ...... 29 Table 4-4: Feature and period codes relevant to this Report ...... 30 Table 5-1: Archaeological periods in South Africa ...... 31 Table 5-2: Summary of the vegetation setting of the Project ...... 38 Table 5-3: Heritage Resources Identified Through the Pre-Disturbance Survey ...... 39 Table 6-1: CS and Field Ratings of Newly Identified Heritage Resources within the Musina- Makhado SEZ Project Area ...... 43 Table 6-2: Summary of the potential direct impact to Burial Grounds and Graves ...... 45 Table 6-3: Summary of potential cumulative impacts...... 47 Table 6-4: Identified heritage risks that may arise for LEDA ...... 48 Table 6-5: Identified unplanned events and associated impacts ...... 49 Table 7-1: Summary of the employment statistics within the regional study area...... 50
LIST OF APPENDICES
Appendix A: Specialist CV Appendix B: HRM Methodology Appendix C: Palaeontological Impact Assessment
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
1 Introduction The Limpopo Economic Development Agency (LEDA) is proposing to develop a Special Economic Zone (SEZ) which spans across parts of both the Musina and Makhdo Local Municipalities of the Limpopo Province (“the Project”). The Project requires Environmental Authorisation (EA) through an Environmental Impact Assessment (EIA) process to comply with the National Environmental Management Act, 1999 (Act No. 107 of 1998) (NEMA). LEDA appointed Delta Built Environment Consultants (Pty) Ltd (hereinafter Delta BEC) to undertake the EIA process while advertising tenders for other consultancies to complete specialist studies in support of this process. LEDA appointed Digby Wells Environmental (hereinafter Digby Wells) to undertake the Heritage Resources Management (HRM) process, inclusive of a Palaeontological Impact Assessment (PIA). Digby Wells completed the HRM process in compliance with Section 38 of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA). This report constitutes the Heritage Impact Assessment (HIA) report for submission to the South African Heritage Resources Agency (SAHRA) and the Limpopo Heritage Resources Authority (LIHRA). The PIA report is included as Appendix C.
1.1 Project Background and Description The Limpopo Provincial Government submitted areas to the Department of Trade and Industry (DTI) for consideration as SEZ developments and subsequently motivated for Musina as the site of the Project. The Musina SEZ will include two components: a light industrial and agro-processing component to the north and the Project (also referred to as the Musina-Makhado SEZ), which will focus on metallurgical and mineral beneficiation activities, to the south. These will complement each other in terms of logistics and their product value chains. Additionally, the Musina Logistics SEZ is also in the planning stages, which will complement both these developments. The light industrial and agro-processing components of SEZ developments are not within the Scope of this HRM process and will not be assessed in this document1. The Project area is adjacent to the National Route 1 (N1) national highway, between the towns of Musina and Makhado2. The Project is located within the Musina and Makhado Local Municipalities of the Vhembe District Municipality (VDM) of the Limpopo Province. Plan 1 presents the regional setting of the Project. The Project area will include the following eight farms:
■ Antrobus 566 MS;
■ Battle 585 MS;
1 These additional developments will be noted for their potential cumulative impacts. Refer to Section 6.3. 2 Previously known as Louis Trichard.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
■ Dreyer 526 MS;
■ Portion 1 of Joffre 584 MS;
■ Lekkerlag 580 MS;
■ Somme 611 MS;
■ Steenbok 565 MS; and
■ Van der Bijl 528 MS.
These properties collectively comprise 8 000 hectares (ha), of which the SEZ development will cover 6 000 ha. Plan 2 presents an overview of this area. Presently, the SEZ includes mixed land uses, several smaller projects and 11 energy and metallurgical plants, comprising:
■ Calcium carbide plant (50 ha);
■ Carbon steel plant (200 ha);
■ Coke plant (500 ha);
■ Ferrochromium plant (500 ha);
■ Ferromanganese plant (100 ha);
■ Lime plant (500 ha);
■ Metal silicon plant (50 ha);
■ Pig Iron plant (600 ha);
■ Power plant (300 ha);
■ Stainless steel plant (500 ha);
■ Silicon-manganese plant (100 ha); and
■ Additional and ancillary infrastructure required for these developments (2 600 ha).
1.2 Project Alternatives LEDA has considered several Project alternatives as part of a feasibility study in 2015 for the SEZ Licence Application (Mott MacDonald, 2015). This assessment considered the economic viability and associated benefits from a range of industries, including agro- processing, logistics and petro-chemicals. These Project alternatives have already been assessed and will not be considered further in this EIA process. This notwithstanding, LEDA is presently considering alternatives in terms of the Project design and layout within the earmarked 6 000 ha. The final infrastructure layout will aim to avoid or reduce significant impacts identified in the various specialist studies. Another alternative to be considered is the “no-go” alternative. Should the Project not obtain approval, or not go ahead for any reason, the potential environmental impacts associated
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
with the development of the SEZ as described in Section 1.1 would not occur. However, the potential benefits associated with the Project would also not occur.
1.3 Terms of Reference To conduct an HRM process in support of the EA application applicable to this Project. Digby Wells completed the HRM process in accordance with Section 38(8) of the NHRA.
1.4 Scope of Work The Scope of Work (SoW) for the specialist HRM process included the compilation of an HIA report to comply with the requirements encapsulated in Section 38(3) of the NHRA. Digby Wells completed the following activities as part of the SoW:
■ Description of the predominant cultural landscape supported through primary and secondary data collection;
■ Assessment of the Cultural Significance (CS) of the identified heritage resources;
■ Identification of potential impacts to heritage resources based on the Project description and Project activities;
■ An evaluation of the potential impacts to heritage resources relative to the sustainable socio-economic benefits that may result from the Project;
■ Recommending feasible management measures and/or mitigation strategies to avoid and/or minimise negative impacts and enhance potential benefits resulting from the Project; and
■ Submission of the HIA report to SAHRA and LIHRA for Statutory Comment as required under Section 38(8) of the NHRA.
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29°30'0"E 29°45'0"E 30°0'0"E 30°15'0"E
Plan 1 ZIMBABWE Beitbridge Project Area 22°15'0"S BOTSWANA 22°15'0"S Musina-Makhado SEZ
MOZAMBIQUE Development Project Limpopo o
SOUTH AFRICA Regional Setting Musina
North West Mpumalanga
le Gauteng SWAZILANDle he Nz Legend SEZ Boundary
Major Town Musina Local Municipality Secondary Town
22°30'0"S Settlement 22°30'0"S
Brombeek Main Road
National Road
River
Tshipise Bandur Mopane Dam
Local Municipality Boundary NWANEDZI DAM
Huntleigh
NZHELELE DAM 22°45'0"S 22°45'0"S
Thulamela Local Municipality Oorwinning FUNDUZI
Wyllie's Poort Waterpoort
Makhado Local Municipality
23°0'0"S 23°0'0"S
Mara Makhado Tshakhuma Sustainability Service Positive Change Professionalism Future Focused Integrity Ratombo Projection: Transverse Mercator Ref #: per.LEA5514.201904.134
Datum: WGS 1984 Revision Number: 1 Buysdorp Levubu Central Meridian: 29°E Date: 29/04/2019
ALBASINIDAM 0 5 10 20 Borchers
Kilometres Elim
1:400 000
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29°48'0"E 29°51'0"E 29°54'0"E 29°57'0"E
22°36'0"S 2/499 833 DU PREEZ 834 22°36'0"S Plan 2 DELFT 499 ERASMUS 529 ALBASINI 524 EMERY 522 RE/524 RE/529 RE/522 RE/525 519 BELLEVUE 534 JAN VAN RENSBURG 525 Musina-Makhado SEZ VAN HEERDEN 519 MASERI PAN 520 Development Project Mopane RE/520 RE/530 RE/520 Project Area GOOSEN 530 3/525
11/529 1/530
Legend 526 DREYER 526 BECK 568
533 SEZ Boundary 1/531 568 HERMANUS 533 568 RE/567 Settlement
National / Arterial Road
834 Main Road 528 VAN DER BIJL 528 SCOTT 567 FRANS 833 22°39'0"S 22°39'0"S Minor Road
2/567 RE/566 ANTROBUS 566 Railway Line
Dam Wall
BURTON 570 DU TOIT 563 Non-Perennial Stream RE/563 RE/565 STEENBOK 565 Dam
575 BUXTON 575 Parent Farm 617 617
Farm Portion
564 GROOT ENDABA 581 GROOTPRAAT 564 581
562 Huntleigh
RE/611 RE/589 SOMME 611 VRIENDEN 589
574 JAPIE 574 22°42'0"S 22°42'0"S
OOM JAN 579 5/589 590 585 OOM JAN 579 BATTLE 585 SOMERVILLE 590 579 LEKKERLAG 580 OOM JAN 586 580 RE/580 OOM JAN 586 WILDGOOSE 577 RE/588 COMMAND 588
577 1/584 1/584 JOFFRE 584
592 RUNDE 592 Sustainability Service Positive Change Professionalism Future Focused Integrity 578 Projection: Transverse Mercator Ref #: per.LEA5514.201904.138 Datum: WGS 1984 Revision Number: 1 RE/2/637 FANIE 578 Central Meridian: 29°E Date: 29/04/2019 587 GENERAL 587 RISSIK 637 1/637 RE/584 0 0.5 1 2 3 593 PYLKOP 593 PHANTOM 640 636 881 22°45'0"S Kilometres CLARA 633 640 22°45'0"S KLEINENBERG 636 COEN BRITZ 881 1/633 1:65 000
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
1.5 Expertise of the Specialist Table 1-1 presents a summary of the expertise of the specialists involved in the compilation of this report. The full CVs of these specialists are included in Appendix A. Table 1-1: Expertise of the specialists
Team Member Bio Sketch
Shannon joined the Digby Wells team in May 2017 as a Heritage Management Intern and has most recently been appointed as a Heritage Resources Management Consultant. Shannon is an archaeologist who
obtained a Master of Science (MSc) degree from the University of the Shannon Hardwick Witwatersrand in 2013, specialising in historical archaeobotany in the Limpopo Province. She is a published co-author of one paper in Journal of ASAPA Member: 451 Ethnobiology. Since joining Digby Wells, Shannon has gained generalist experience through the compilation of Notification of Intent to Develop Years’ Experience: (NID) applications as well as Heritage Scoping Reports (HSRs) and HIAs. Her other experience includes compiling a Community Health, Safety and 2 Security Management Plan (CHSSMP) and researching Artisanal and Small-Scale Mining for input into a Livelihood Restoration Framework (LRF). Shannon’s experience in the field includes pre-disturbance surveys in South Africa and fieldwork in Malawi.
Justin is the Divisional Manager for Social and Heritage Services at Digby Wells. Justin joined the company in August 2011 as an archaeologist and was subsequently made Divisional Manager in 2018. He obtained his
Master of Science (MSc) degree in Archaeology from the University of the
Witwatersrand in 2008, specialising in the Southern African Iron Age. Justin also attended courses in architectural and urban conservation Justin du Piesanie through the University of Cape Town’s Faculty of Engineering and the Built Environment Continuing Professional Development Programme in 2013. ASAPA Member 270 Justin is a professional member of the Association of Southern African Professional Archaeologists (ASAPA), and accredited by the association’s ASAPA CRM Unit Cultural Resources Management (CRM) section. He is also a member of ICOMOS Member the International Council on Monuments and Sites (ICOMOS), an advisory 14274 body to the UNESCO World Heritage Convention. He has over 12 years IAIAsa Member combined experience in HRM in South Africa, including heritage assessments, archaeological mitigation, grave relocation, NHRA Section Years’ Experience: 12 34 application processes, and Conservation Management Plans (CMPs). Justin has gained further generalist experience since his appointment at Digby Wells in Botswana, Burkina Faso, Cameroon, the Democratic Republic of Congo, Liberia, Malawi, Mali, Senegal and Tanzania on projects that have required compliance with IFC requirements. Furthermore, Justin has acted as a technical expert reviewer of HRM projects undertaken in Cameroon, Malawi and Senegal.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
1.6 Structure of the Report Table 1-2 presents the structure for the remainder of the report and indicates where each section meets the information requirements encapsulated in the NHRA and Appendix 6 of Government Notice Regulation (GN R) 326 of 07 April 2017. Table 1-2: Structure of the report
Description App. 6 NHRA Section
Page ii Declaration that the report author(s) is (are) independent. (b) - and iii
An indication of the scope of, and the purpose for which, the 1.3 (c) - report was prepared. 1.4
Details of the person who prepared the report and their (a) - 1.5 expertise to carry out the specialist study.
Outlines the legislative framework relevant to the specialist - - 2 heritage study. Identifies the specific constraints and limitations of the HIA, including any assumptions made and any uncertainties or (i) - 3 gaps in knowledge.
4 Describes the methodology employed in the compilation of (e) - Appendix this HIA. B
An indication of the quality and age of base data used for (cA) - 4.4 the specialist report. The duration, date and season of the site investigation and the relevance of the season to the outcome of the (d) - 4.5 assessment.
Provides the baseline cultural landscape. - 38(3)(a) 5
Motivates for the defined CS of the identified heritage - 38(3)(b) 6 resources and landscape.
A description of the potential impacts to heritage resources by project related activities, including:
- Existing impacts on the site; - Possible risks to heritage resources; (cB) 38(3)(c)- 6 - Cumulative impacts of the proposed development; - Acceptable levels of change; and - Heritage-related risks to the project.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Description App. 6 NHRA Section A description of the findings and potential implications of such findings on the impact of the proposed activity or (j) 38(3)(c) activities.
Details of an assessment of the specific identified sensitivity of the site related to the proposed activity or activities and (f) - its associated structures and infrastructure, inclusive of a site plan identifying site alternatives. Considers the development context to assess the socio- economic benefits of the project in relation to the presented - 38(3)(d) 7 impacts and risks. A description of any consultation process that was undertaken during the course of preparing the specialist (o) 38(3)(e) report and the results of such consultation. 8 A summary and copies of any comments received during any consultation process and where applicable all (p) 38(3)(e) responses thereto.
Details the specific recommendations based on the - contents of the HIA.
An identification of any areas to be avoided, including (g) buffers. Any mitigation measures for inclusion in the Environmental (k) 38(3)(g) 9 Management Programme (EMPr)
Any conditions for inclusion in the environmental (l) authorisation.
Any monitoring requirements for inclusion in the EMPr or (m) environmental authorisation.
A reasoned opinion—
(i) whether the proposed activity, activities or portions
thereof should be authorised; (iA) regarding the acceptability of the proposed activity or activities; and 9 (n) 38(3)(g) (ii) if the opinion is that the proposed activity, activities 10 or portions thereof should be authorised, any avoidance, management and mitigation measures that should be included in the EMPr, and where applicable, the closure plan
Collates the most salient points of the HIA and concludes 38(3)(f) with the specific outcomes and recommendations of the - 10 38(3)(g) study.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Description App. 6 NHRA Section
Lists the source material used in the development of the (cA) - 11 report.
A map superimposing the activity including the associated structures and infrastructure on the environmental (h) - Plan 4 sensitivities of the site including areas to be avoided, including buffers
Any other information requested by the competent authority. (q) - -
2 Legislative and Policy Framework The HRM process is governed by the national legislative framework. This section provides a summary of the relevant legislation pertaining to the conservation and responsible management of heritage resources. Table 2-1: Applicable Legislation Considered in the HRM Process
Applicable legislation used to compile the report Reference where applied
Constitution of the Republic of South Africa, 1996 (Act No. 108 of 1996)
Section 24 of the Constitution states that everyone has The HRM process was undertaken to the right to an environment that is not harmful to their identify heritage resources and determine health or well-being and to have the environment heritage impacts associated with the protected, for the benefit of present and future Project. generations, through reasonable legislative and other As part of the HRM process, applicable measures, that – mitigation measures, monitoring plans i. Prevent pollution and ecological and/or remediation were recommended to degradation; ensure that any potential impacts are ii. Promote conservation; and managed to acceptable levels to support iii. Secure ecologically sustainable the rights as enshrined in the Constitution. development and use of natural resources while promoting justifiable economic and social development
National Environmental Management Act, 1998 (Act No. 107 of 1998) The NEMA, as amended, was set in place in The application process was undertaken in accordance with section 24 of the Constitution of the accordance with the principles of Section 2 Republic of South Africa. Certain environmental of the NEMA as well as with the EIA principles under NEMA have to be adhered to, to inform Regulations, promulgated in terms of decision making on issues affecting the environment. NEMA. Section 24 (1)(a), (b) and (c) of NEMA state that: The potential impact on the environment, socio-
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Applicable legislation used to compile the report Reference where applied economic conditions and cultural heritage of activities that require authorisation or permission by law and which may significantly affect the environment, must be considered, investigated and assessed prior to their implementation and reported to the organ of state charged by law with authorizing, permitting, or otherwise allowing the implementation of an activity. The Environmental Impact Assessment (EIA) Regulations, GN R 982 were published on 04 December 2014 and promulgated on 08 December 2014. Together with the EIA Regulations, the Minister also published GN R 983 (Listing Notice No. 1), GN R 984 (Listing Notice No. 2) and GN R 985 (Listing Notice No. 3) in terms of Sections 24(2) and 24D of the NEMA, as amended.
GN R 982: Environmental Impact Assessment Regulations, 2014 (as amended by GN R 326 of 7 April 2017)
These three listing notices set out a list of identified activities which may not commence without an Environmental Authorisation from the relevant Competent Authority through one of the following processes: ▪ Regulation GN R 983 (as amended by GN R 327) - Listing Notice 1: This listing notice Refer to the Notification of Intent to provides a list of various activities which require Develop (NID) for a full description of the environmental authorisation and which must Listed Activities triggered by the proposed follow a basic assessment process. Project. ▪ Regulation GN R 984 (as amended by To comply with the regulations, an EIA GN R 325) – Listing Notice 2: This listing notice process must be completed in support of provides a list of various activities which require Environmental Authorisation in terms of environmental authorisation and which must Listing Notice 2. This HIA was completed follow an environmental impact assessment to inform the EIA process to comply with process. Section 24 of the NEMA. ▪ Regulation GN R 985 (as amended by GN R 324) – Listing Notice 3: This notice provides a list of various environmental activities which have been identified by provincial governmental bodies which if undertaken within the stipulated provincial boundaries will require environmental authorisation. The basic assessment process will need to be followed.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Applicable legislation used to compile the report Reference where applied
National Water Act, 1998 (Act No. 36 of 1998) (NWA) An environmental assessment was Part 7 of the NWA outlines the requirements for undertaken in compliance with the NEMA individual applications for licences and Part 8 outlines and NEMA EIA Regulations, which also the requirements in terms of compulsory licences for satisfies the requirements of the NWA and water use in respect of a specific resource. may supplement the Water Use The responsible authority may request additional Application (WUL). information from an applicant in terms of Part 7 or Part This HIA was completed to inform the 8. Such additional information may include an environmental assessment and comply environmental or other assessment to be undertaken in with Section 24 of the NEMA and Section terms of the NEMA and which is to be considered 38(8) of the NHRA. alongside the application.
National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA)
The NHRA is the overarching legislation that protects and regulates the management of heritage resources in South Africa, with specific reference to the following Sections: ▪ 5. General principles for HRM The HIA was compiled to comply with ▪ 6. Principles for management of heritage Section 5, 38(3), (4) and (8) of the NHRA. resources This HIA was submitted to the responsible ▪ 7. Heritage assessment criteria and grading HRAs, which in this instance is SAHRA ▪ 38. Heritage resources management and LIHRA. The Act requires that Heritage Resources Authorities (HRAs), be notified as early as possible of any developments that may exceed certain minimum thresholds in terms of Section 38(1), or when assessments of impacts on heritage resources are required by other legislation in terms of Section 38(8) of the Act.
NHRA Regulations, 2000 (GN R 548)
The NHRA Regulations regulate the general provisions and permit application process in respect of heritage resources included in the national estate. Applications must be made in accordance with these regulations. Digby Wells completed the HRM process The following Chapters are applicable to this taking cognisance of the applicable assessment: regulations. The proposed mitigation ▪ II. Permit Applications and General Provisions strategies and management measures for Permits; must comply with these requirements. ▪ III: Application for Permit: National Heritage Site, Provincial Heritage Site, Provisionally- Protected Place or Structure older than 60 years;
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Applicable legislation used to compile the report Reference where applied
▪ IV: Application for Permit: Archaeological or Palaeontological or Meteorite; ▪ IX: Application for Permit: Burial Grounds and Graves; ▪ X: Procedure for Consultation regarding Protected Area; ▪ XI: Procedure for Consultation regarding Burial Grounds and Graves; and ▪ XII: Discovery of Previously Unknown Graves.
Special Economic Zone Act, 2014 (Act No. 16 of 2014), as amended The Musina-Makhado SEZ must be The Act provides for the designation, promotion, gazetted in terms of the Act. The Act development, operation and management of Special makes provision for special measures that Economic Zones to promote targeted economic do not apply outside of this zone, but the activities to contribute towards the realisation of SEZ must comply with the requirements of economic growth and development goals. the Act. Section 4 of the Act outlines the purpose of the SEZ and Digby Wells completed the HRM process such a zone must be designated and managed taking cognisance of these regulations. according to the requirements outlined in Chapter 5 of the Act.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Table 2-2: Applicable policies considered in the HRM process
Applicable policies used to compile the report Reference where applied
SAHRA Archaeology, Palaeontology and Meteorites (APM) Guidelines: Minimum Standards for the Archaeological and Palaeontological Components of Impact Assessment
Reports (2007)
The guidelines provide the minimum standards that must be adhered to for the compilation of a HIA and/or PIA report. Chapter II Section 7 outlines the minimum requirements for inclusion in the heritage assessment as follows:
▪ Background information on the Project; ▪ Background information on the cultural baseline; The HIA and PIA reports were compiled to adhere to the ▪ Description of the properties or affected environs; minimum standards as defined ▪ Description of identified sites or resources; by Chapter II of the SAHRA APM ▪ Recommended field rating of the identified sites to comply Guidelines (2007) with Section 38 of the NHRA; ▪ A statement of Cultural Significance in terms of Section 3(3) of the NHRA; and ▪ Recommendations for mitigation or management of identified heritage resources. Chapter II, Section 8 outlines the minimum requirements for a PIA report. The information requirements are similar as for the HIA report, but must additionally include a 1:50 000 geological map showing the geological context of the Project.
3 Constraints and Limitations Digby Wells encountered constraints and limitations during the compilation of this report. Table 3-1 presents an overview of these limitations and the consequences. Table 3-1: Constraints and Limitations
Description Consequence
Whilst every attempt was made to obtain the The cultural heritage baseline presented in latest available information, the reviewed Section 5 below is considered accurate, but may literature does not represent an exhaustive list of not include new data or information which may information sources for the various study areas. not have been made available to the public.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Description Consequence
Heritage resources that may have been identified through previously-completed heritage It is assumed the previously recorded heritage assessments within the Project area boundary as resources are accurate and true. sourced from SAHRIS were not verified during the heritage survey. Every effort was made to cover the extent of the The final infrastructure design layout was not study area3. The survey was focused; on areas available at the time of the survey or compilation that were characterised by more open vegetation of this report. and where visibility was at its maximum. Some heritage resources may not have been identified. Previously unidentified heritage resources may Whilst every attempt was made to survey the be encountered. Should this occur, LEDA must extent of the site-specific study area, this report alert the HRAs of the find and may need to enlist does not present an exhaustive list of identified the services of a suitably qualified archaeologist heritage resources. or palaeontologist to advise them on the way forward.
These properties were not surveyed by a At the time of the pre-disturbance survey, access suitably-qualified heritage consultant. was not possible to the following properties: Battle 585 MS and Portion 1 of Joffre 584 MS. Previously unidentified heritage resources may be encountered. Should this occur, LEDA must Additionally, the area of Dreyer 526 MS north of alert the HRAs of the find and may need to enlist the R525 road and the area of Antrobus 566 MS the services of a suitably qualified archaeologist east of the N1 were not accessible during the or palaeontologist to advise them on the way pre-disturbance survey. forward.
The reviewed literature, previously-completed heritage assessments and the results of the field Archaeological and palaeontological resources survey are in themselves limited to surface commonly occur at subsurface levels. These observations. types of resources cannot be adequately Subsurface tangible heritage may be exposed recorded or documented by assessors without during Project activities. Should this occur, LEDA destructive and intrusive methodologies and must alert the HRAs of the find and may need to without the correct permits issued in terms of enlist the services of a suitably qualified Section 35 of the NHRA. archaeologist or palaeontologist to advise them on the way forward.
3 Refer to Section 4.1 for a description of the study area.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Description Consequence
The HRM process, including the impact assessment and mitigation measures, considered This assessment was informed by information all information available at the time of received from LEDA and DeltaBEC. compilation. Digby Wells assumes this information is true and accurate.
4 Methodology
4.1 Defining the Study Area Heritage resources do not exist in isolation to the greater natural and social environment, including the socio-cultural, socio-economic and socio-political environments. In addition, the NHRA requires the grading of heritage resources in terms of national, provincial and local concern based on their importance and consequent official (i.e. State) management effort required. The type and level of baseline information required to adequately predict heritage impacts varies between these categories. Three ‘concentric’ study areas were defined for the purposes of this study, and include:
■ The site-specific study area: the farm portions extent associated with the proposed Project, including a 500 m buffer area. The site-specific study area may extend linearly, in which case the site-specific study area will include the linear development and a 200 m buffer on either side of the footprint;
■ The local study area: the area most likely to be influenced by any changes to heritage resources in the Project area or where Project development could cause heritage impacts. Defined as the area bounded by the local municipality, in this instance the Musina and Makhado Local Municipalities, with particular reference to the immediate surrounding properties and/or farms. The local study area was specifically examined to offer a backdrop to the socio-economic conditions within which the proposed development will occur. The local study area furthermore provided the local development and planning context that may contribute to cumulative impacts; and
■ The regional study area: the area bounded by the district municipality, which here is VDM. Where necessary, the regional study area may be extended outside the boundaries of the district municipality to include much wider regional expressions of specific types of heritage resources and historical events. The regional study area also provided the regional development and planning context that may contribute to cumulative impacts.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
4.2 Statement of Cultural Significance Digby Wells designed the significance rating process to provide a numerical rating of the CS of identified heritage resources. This process considers heritage resources assessment criteria set out in subsection 3(3) of the NHRA, which determines the intrinsic, comparative and contextual significance of identified heritage resources. A resource’s importance rating is based on information obtained through review of available credible sources and representativity or uniqueness (i.e. known examples of similar resources to exist). The rationale behind the heritage value matrix takes into account that a heritage resource’s value is a direct indication of its sensitivity to change (i.e. impacts). Value, therefore, was determined prior to completing any assessment of impacts. The matrix rated the potential, or importance, of an identified resource relative to its contribution to certain values – aesthetic, historical, scientific and social. Resource significance is directly related to the impact on it that could result from Project activities, as it provided minimum accepted levels of change to the resource.
4.3 Definition of Heritage Impacts Potential impacts to heritage resources may manifest differently across geographical areas or diverse communities when one considers the simultaneous effect to the tangible resource and social repercussions associated with the intangible aspects. Furthermore, potential impacts may concurrently influence the CS of heritage resources. This assessment therefore considers three broad categories adapted from Winter & Baumann (2005, p. 36). Table 4-1 presents a summary of these impacts. Table 4-1: Impact Definition
Category Description
Affect the fabric or physical integrity of the heritage resource, for example destruction of an archaeological site or historical building. Direct impacts Direct Impact may be the most immediate and noticeable. Such impacts are usually ranked as the most intense, but can often be erroneously assessed as high-ranking.
Occur later in time or at a different place from the causal activity, or as a result of a complex pathway. For example, restricted access to a heritage resource resulting in the gradual erosion of its CS that may be dependent Indirect Impact on ritual patterns of access. Although the physical fabric of the resource is not affected through any direct impact, its significance is affected to the extent that it can ultimately result in the loss of the resource itself.
Result from in-combination effects on heritage resources acting within a host of processes that are insignificant when seen in isolation, but which Cumulative Impact collectively have a significant effect. Cumulative effects can be: ▪ Additive: the simple sum of all the effects, e.g. the reclamation of a historical Tailings Storage Facility (TSF) will minimise the sense of
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Category Description the historic mining landscape. ▪ Synergistic: effects interact to produce a total effect greater than the sum of the individual effects, e.g. the removal of all historical TSFs will sterilise the historic mining landscape. ▪ Time crowding: frequent, repetitive impacts on a particular resource at the same time, e.g. the effect of regular blasting activities on a nearby rock art site or protected historical building could be high. ▪ Neutralizing: where the effects may counteract each other to reduce the overall effect, e.g. the effect of changes from a historic to modern mining landscape could reduce the overall impact on the sense-of-place of the study area. ▪ Space crowding: high spatial density of impacts on a heritage resource, e.g. density of new buildings resulting in suburbanisation of a historical rural landscape.
4.4 Secondary Data Collection Data collection assists in the development of a cultural heritage baseline profile of the study area under consideration. Qualitative data primarily sourced from secondary information sources, i.e. desktop literature review, informed this HIA. The researcher surveyed diverse information repositories to identify appropriate relevant information sources while considering their credibility and relevance. These credible, relevant sources were then critically reviewed to:
■ Gain an understanding of the cultural landscape within which the proposed Project is located; and
■ Identify any potential fatal flaws, sensitive areas, current social complexities and issues and known or possible tangible heritage.
Repositories that were surveyed included the South African Heritage Resources Information System (SAHRIS), online/electronic journals and platforms and select internet sources. This HIA includes a summary and discussion of the most relevant findings. Table 4-2 lists the sources consulted in the literature review (refer to Section 11 for more detailed references). Table 4-2: Qualitative Data Sources
Reviewed Qualitative Data
Databases
Genealogical Society of South Africa (GSSA) University of the Witwatersrand (WITS) database (2011) Archaeological Database (2010)
SAHRIS SAHRIS Palaeo-sensitivity Map (PSM)
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Reviewed Qualitative Data
SAHRIS Cases
Case ID 65 Case ID 4577 Case ID 7890 Case ID 11558
Cited Text
Behrens & Swanepoel, 2008 Biemond, 2014 Clark, 1982
Deacon & Deacon, 1999 Delius, et al., 2014 Esterhuysen & Smith, 2007
Huffman, 2007 Huffman & Van der Walt, 2011 Makhado Local Municipality, 2018
Mitchell, 2002 Mott MacDonald, 2015 Mucina & Rutherford, 2010
Musina Local Municipality, Nel, 2012 Open Up, 2017 2018
Roodt, 2011 Roodt & Roodt, 2014 Schapera, 1953
Silidi & Matenga, 2013 Smuts, 2018 Swanepoel, et al., 2008
VDM, 2017 Winter & Baumann, 2005
Table 4-3 below lists the sources of historical imagery. Historical layering is a process whereby diverse cartographic sources from various time periods are layered chronologically using Geographic Information Systems (GIS). The rationale behind historical layering is threefold, as it:
■ Enables a virtual representation of changes in the land use of a particular area over time;
■ Provides relative dates based on the presence or absence of visible features; and
■ Identified potential locations where heritage resources may exist within an area.
Section 5.2 includes a discussion of the results of the historical layering. Table 4-3: Aerial imagery considered
Aerial photographs
Job Flight Photo no. Map ref. Area Year Ref. no. plan
National Geospatial 410 13 8805 2229 Beit Bridge and Messina 1958 Institute (NGI)
410 13 8807 2229 Beit Bridge and Messina 1958 NGI
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Aerial photographs
Job Flight Photo no. Map ref. Area Year Ref. no. plan
410 13 8809 2229 Beit Bridge and Messina 1958 NGI
410 14 8210 2229 Beit Bridge and Messina 1958 NGI
410 14 8212 2229 Beit Bridge and Messina 1958 NGI
410 15 8256 2229 Beit Bridge and Messina 1958 NGI
4.5 Primary Data Collection Shannon Hardwick undertook a pre-disturbance survey of the Project area between 11 and 14 March 2019. The survey was a combination of vehicular and pedestrian: areas with more open vegetation were inspected on foot away from the informal roads that were used to navigate the Project area. The survey was non-intrusive (i.e. no sampling was undertaken) with the aim to:
■ Visually record the current state of the cultural landscape; and
■ Record a representative sample of the visible, tangible heritage resources present within the development footprint area, site-specific study area and greater study area.
Identified heritage resources were recorded as waypoints using a handheld GPS device. The heritage resources were also recorded through written and photographic records. Plan 4 presents the results of the pre-disturbance survey, including the waypoints and GPS tracks.
4.6 Site Naming Convention Heritage resources identified by Digby Wells during the field survey are prefixed by the SAHRIS case identification generated for this Project. Information on the relevant period or feature code and site number follows (e.g. 13969/BGG-001). The site name may be shortened on plans or figures to the period/feature code and site number (e.g. BGG-001). Table 4-4 presents a list of the relevant period and feature codes. Table 4-4: Feature and period codes relevant to this Report
Feature or Period Code Reference
BGG Burial Grounds and Graves
SA Stone Age
STE (Historical) Structure
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Heritage resources identified through secondary data collection were prefixed by the relevant SAHRIS case or map identification number (where applicable) and the original site name as used by the author of that assessment (e.g. 11558/Vriendin 1).
5 Cultural Heritage Baseline Description4 The cultural heritage baseline description considered the predominant cultural landscape based on the identified heritage resources within the regional and local study area. Table 5-1 presents a summary of the relevant archaeological periods. Plan 3 presents an overview of these heritage resources and their spatial relation to the Project area. Table 5-1: Archaeological periods in South Africa
2 million years ago (mya) to 250 Early Stone Age (ESA) thousand years ago (kya) The Stone Age Middle Stone Age (MSA) 250 kya to 20 kya
Later Stone Age (LSA) 20 kya to 500 CE (Common Era5)
Early Farming communities 500 to 1400 CE (EFC) Farming Communities Late Farming Communities 1100 to 1800 CE (LFC)
1500 CE to 1994 Historical Period - (Behrens & Swanepoel, 2008)
Adapted from Esterhuysen & Smith (2007) In total, 187 heritage resources were identified within the regional, local and site-specific study areas. Figure 5-1 illustrates the breakdown of the identified heritage resources. Expressions of resources associated with the palaeontological, Stone Age and Farming Community periods have been recorded within the greater study area. However, the historical period, including the historical built environment and burial grounds and graves, dominate the tangible heritage resources identified within the area under consideration.
4 A description of the geological context and palaeontological sensitivities is included in the PIA report (Refer to Appendix C) 5 Common Era (CE) refers to the same period as Anno Domini (“In the year of our Lord”, referred to as AD): i.e. the time after the accepted year of the birth of Jesus Christ and which forms the basis of the Julian and Gregorian calendars. Years before this time are referred to as ‘Before Christ’ (BC) or, here, BCE (Before Common Era).
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Archaeological - Indeterminate Farming Community
Archaeological - Indeterminate Stone Age
Archaeological - LFC
23.0% 5.9% 3.7% Archaeological - MSA 2.1%
Archaeological - MSA/LSA
20.9% 32.6% Burial Grounds & Graves
Cultural Landscape
Historical Built Environment 6.4% 2.7% 0.5% Indeterminate archaeological 1.6% 0.5%
Intangible / Living
Mixed
Figure 5-1: Heritage resources identified within the greater study area
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29°45'0"E 29°48'0"E 29°51'0"E 29°54'0"E
22°33'0"S Plan 3 22°33'0"S
Musina-Makhado SEZ
Development Project
HRM Matrix Plan
Legend
SEZ Boundary
HRM Site Matrix 22°36'0"S 22°36'0"S Settlement
National / Arterial Road
Mopane Main Road
Minor Road Railway Line
Dam Wall
Non-Perennial Stream Perennial Stream
22°39'0"S 22°39'0"S Dam
Flood Bank / Non-Perennial Extent
Huntleigh
22°42'0"S 22°42'0"S
Sustainability Service Positive Change Professionalism Future Focused Integrity Projection: Transverse Mercator Ref #: per.LEA5514.201904.133 Datum: WGS 1984 Revision Number: 1 Central Meridian: 29°E Date: 29/04/2019
0 0.5 1 2 3
Kilometres
22°45'0"S 1:85 000 www.digbywells.com © Digby Wells Environmental 29°45'0"E 29°48'0"E 29°51'0"E 29°54'0"E
Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
The Stone Age in southern Africa comprises three broad phases, defined by the lithic tools and other material culture produced by the various hominid species through time. These phases are: the ESA, the MSA and the LSA. Archaeological evidence suggests that hominids have inhabited the Limpopo Province since the ESA. No expressions of the ESA have been identified within the regional study area, and so this period is not considered further in this report. The MSA dates from approximately 300 kya to 20 kya. Early MSA lithic industries are characterised by high proportions of blades, which have been minimally modified and which were created using the Levallois technique (Clark, 1982; Deacon & Deacon, 1999). The use of good quality raw material defines this period, as does the use of bone tools, ochre, beads and pendants. MSA artefacts are usually associated with water sources, for example pans and the Limpopo River. However, these finds are often not found in situ and therefore offer limited contextual information. The MSA accounts for 2.1% of the identified heritage resourced, mixed MSA/LSA for 3.7% and indeterminate Stone Age artefacts for an additional 6.4%. The Stone Age is represented in the regional study area as isolated artefacts, artefacts embedded in the surface matrix, and low- and high-density surface scatters (Silidi & Matenga, 2013; Smuts, 2018). The LSA dates between 40 kya to the historical period. LSA lithics are specialised where specific tools have been created for specific tasks (Mitchell, 2002). Bone points are included in LSA assemblages, which also commonly include diagnostic tools such as scrapers and segments. As with the MSA artefacts, LSA artefacts are usually associated with water sources and are not usually found in situ. In southern Africa, the LSA is closely associated with hunter-gatherers. This period is further defined by evidence of ritual practices and complex societies (Deacon & Deacon, 1999). This is commonly expressed through rock art. No such expressions of the LSA were recorded within the greater study area. Hunter-gatherers were later followed by the various peoples of the Farming Community period. This time is characterised by the movements of Bantu-speaking agro-pastoralists moving into southern Africa and is divided into an early and late phase (EFC and LFC). EFC and LFC sites can be identified through secondary tangible surface indicators, such as ceramics and evidence for the domestication of animals (such as faunal remains or dung deposits). No expressions of the EFC were identified within the regional study area, and so this period is not considered further in this report. The LFC accounts for 20.9% of the identified heritage resources and indeterminate Farming Community artefacts account for an additional 2.7%. LFC sites can be identified through secondary tangible surface indicators, such as ceramics and evidence for domesticated animals, i.e. dung deposits or faunal remains. These resources provide motivation for settlement and possible trade networks (Delius, et al., 2014) and are distributed across the region. Stonewalling is the most visible indicator of LFC settlements. Stonewalls attest to the complex processes of development and decline over several years (Delius, et al., 2014). No
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514 examples of such archaeological material were identified within the regional study area in the literature. The LFC can also be identified through evidence for temporary or permanent settlement. This includes cattle posts which have been identified along the escarpment and settlements that were briefly occupied and which have been identified close to the workable soils along the Limpopo River (Huffman & Van der Walt, 2011).Ethnographic evidence suggests that the cattle posts may be associated with users of the Letsibogo ceramics; these users may have been the baKaa (Schapera, 1953; Huffman, 2007; Huffman & Van der Walt, 2011; Biemond, 2014). The Letsibogo ceramics are characterised by lines of punctates separated by red and black zones (Huffman, 2007; Huffman & Van der Walt, 2011; Biemond, 2014). These ceramics date between 1500 CE and 1700 CE. Within the identified literature, the LFC is represented by:
■ Isolated examples and low- density scatters of ceramic fragments (Roodt, 2011; Silidi & Matenga, 2013; Smuts, 2018);
■ Deposits associated with cattle kraals (Silidi & Matenga, 2013);
■ Sites of low- to high-complexity (Silidi & Matenga, 2013); and
■ Stonewalling (Roodt, 2011; Silidi & Matenga, 2013).
The LFC transition to the historical period is characterised by the emergence of large agricultural settlements associated with the baTswana. Archaeological excavations within the regional study area indicate that the baTswana occupation of the area may have been brief (Nel, 2012). As demonstrated in the history of the baKwena, periods of political turbulence caused disruptions during the 18th and 19th centuries (Schapera, 1953). It is these disruptions that are suggested to be the cause of the ephemeral remains of the archaeological sites (Nel, 2012). The historical period6 is commonly regarded as the period characterised by contact between Europeans and Bantu-speaking African groups and the written records associated with this interaction. However, the division between the LFC and historical period is artificial, as there is a large amount of overlap between the two.
6 In southern Africa, the last 500 years represents a formative period that is marked by enormous internal economic invention and political experimentation that shaped the cultural contours and categories of modern identities outside of European contact. This period is currently not well documented, but is being explored through the 500 Year Initiative (Swanepoel, et al., 2008).
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Historical heritage resources associated with the early settlement of the region make up 32.6% of the identified heritage resources in the area under consideration, with burial grounds and graves accounting for an additional 23%. Burial grounds and graves account for a further 10% of the records. These are expressed as single graves and burial grounds with fewer than 20 graves and one burial ground of indeterminate size (Roodt, 2011; Silidi & Matenga, 2013; Roodt & Roodt, 2014). Historical heritage resources within the regional study area are represented as:
■ Deposits associated with cattle kraals and historical structures (Silidi & Matenga, 2013);
■ Sites of low and high complexity (Silidi & Matenga, 2013);and
■ Structural remains, standing buildings, remains of functional structures and the remains of complexes (i.e. werwe or farmsteads) (Silidi & Matenga, 2013; Smuts, 2018).
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Figure 5-2: Current Environment at the time of the pre-disturbance survey
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
5.1 Existing Environment The Project is considered a “greenfields development” in that there has been minimal investment and development on the affected properties. This notwithstanding, the Project area has been greatly disturbed through anthropogenic activity, including the grazing of livestock and individual residences. Some of the modern structures identified within the Project area during the pre-disturbance survey appear to have been used as tourist accommodation. Table 5-2 presents a summary of the natural vegetation within the Project area. Table 5-2: Summary of the vegetation setting of the Project
Biome Bio-region Vegetation Type
Musina Mopane Bushveld (SVmp 1)
Open woodland to moderately-closed shrubveld located on undulating
to irregular plains, with some hills present. This vegetation type is associated with layers of the Archaean Beit Bridge Complex, although it also occurs with younger Karoo sandstones and basalts. This unit is considered to be Least Threatened and roughly 3% of this type has been transformed. Much of this transformation is due to cultivation. Erosion is high to moderate. This unit is the most diverse mopaneveld type in South Africa and has a complex spatial relationship with Savanna Mopane SVmp 2.
Limpopo Ridge Bushveld (SVmp 2) Moderately open savanna with a poorly-defined ground layer location on extremely irregular plains with ridges and hills. This unit is associated with the Beit Bridge Complex but also occurs with the sediments and basalts of the Karoo Supergroup. Soil is shallow and ranges from gravel and sand to calcareous and clayey. This unit is also considered Least Threatened with approximately 1% transformed due to mining and cultivation
Adapted from Mucina and Rutherford (2010)
5.2 Results from the pre-disturbance survey Table 5-3 includes a description of the heritage resources identified during the survey. Plan 4 presents the results of the pre-disturbance survey. Figure 5-3 includes select photographs of the heritage resources identified during the pre-disturbance survey. The historical imagery shows a landscape that is predominantly characterised by the flora expected of the region, although some plots of cultivated land were present in the imagery. No additional points of interest were identified in the historical imagery. No structures were visible in the aerial imagery, despite the presence of cultivated plots of land within the Project area. This suggests that structures that may have been associated with those plots were not visible on the imagery. In Digby Wells’ opinion, based on the visual
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
features of the two structures, these are older than 60 years and Digby Wells recommends that LEDA treat these as historical structures in full compliance with Section 34 of the NHRA. Table 5-3: Heritage Resources Identified Through the Pre-Disturbance Survey7
Site Name Description
Small burial ground with three visible graves, although there is space within the burial ground for more. The graveyard is demarcated with a white wire fence with a gate and BGG-001 is in good condition, although it was overgrown at the time of the survey. All three graves belong to the De Bruin family and date between 1960 and 1961. The date on the third headstone was not legible. Includes one child grave.
Single grave belonging to a member of the Manganya family, dated to 1945. The grave was not fenced off and had a granite headstone and brick fittings. The BGG-002 graveyard is near abandoned buildings of a werf of unknown age. The area near the grave has been used to deposit construction rubble and metal rubbish.
Isolated single MSA flake with flake scars and a snap fracture. Recovered from within SA-001 a watercourse and as such is ex situ with limited contextual information. Structural remains including what appear to be deep foundations or similar structures STE-001 made of brick and cement. Presently being used to deposit rubbish. The age of this structure has not been determined. This structure is in close proximity to STE-002.
Building in a state of disrepair. The building appears to have been a residence with a wraparound veranda. All exterior windows and doors have been bricked up, except for the entrance. The roof is present over the main structure, but has collapsed over the STE-002 veranda. One florescent light was attached to the ceiling. The age of this structure has not been verified, but it is assumed to be older than 60 years. This structure is in close proximity to STE-001.
7 In accordance with new SAHRA procedures, the GPS co-ordinates of these heritage resources have not been included in documents available to the public.
Digby Wells Environmental 39
Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Figure 5-3: Photographs of heritage resources identified during the pre-disturbance survey. A.) SA-001, B.) and C.) two sides of STE-002; D.) BGG-001, E.) STE-001 and F.) BGG-002
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29°48'0"E 29°51'0"E 29°54'0"E 29°57'0"E
22°36'0"S 22°36'0"S Plan 4
Musina-Makhado SEZ
Development Project Mopane
Pre-disturbance Survey
BGG-001
Legend
SEZ Boundary
Settlement
Heritage Points
Field Tracks
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Main Road SA-001 BGG-002 Minor Road
Railway Line
STE-001 Dam Wall STE-002
Non-Perennial Stream
Dam
Huntleigh
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Sustainability Service Positive Change Professionalism Future Focused Integrity Projection: Transverse Mercator Ref #: per.LEA5514.201904.137 Datum: WGS 1984 Revision Number: 1 Central Meridian: 29°E Date: 29/04/2019
0 0.5 1 2 3 22°45'0"S 22°45'0"S Kilometres
1:65 000 www.digbywells.com © Digby Wells Environmental 29°48'0"E 29°51'0"E 29°54'0"E 29°57'0"E
Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
6 Impact Assessment
6.1 Cultural Significance of the Identified Landscape Heritage resources are intrinsic to the history and beliefs of communities. They characterise community identity and cultures and are finite, non-renewable and irreplaceable. Considering the innate value of heritage resources, HRM acknowledges that these have lasting worth as evidence of the origins of life, humanity and society. Notwithstanding the inherent value ascribed to heritage, it is incumbent on the assessor to determine the significance of these resources to allow for the implementation of appropriate management. This is achieved through assessing the value of heritage resources relative to the prescribed criteria encapsulated in policies and legal frameworks. This section presents a statement of CS as is relevant to newly-identified heritage resources and the greater cultural landscape of the site-specific study area. The statement of significance considers the importance or the contribution of the identified heritage resources and the landscape to four broad value categories: aesthetic, historical, scientific and social, to summarise the CS and other values described in Section 3(3) of the NHRA. Three categories of heritage resources were recorded during the field survey of the Musina- Makhado SEZ Development site-specific study area. These comprised:
■ Archaeological – Stone Age (1 records);
■ Burial grounds and graves (2 records); and
■ Historical built environment (2 records).
The assessment of the CS and Field Ratings demonstrated that the identified have a CS designation ranging from negligible to very-high. Table 6-1 presents a summary of this assessment. Sites of the same type that share the same CS have been grouped together in terms of the impact assessment (refer to Section 6.2).
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Table 6-1: CS and Field Ratings of Newly Identified Heritage Resources within the Musina-Makhado SEZ Project Area
Minimum Resource ID Type Description Recommended 8
Social Mitigation
Historic
Scientific
Aesthetic
INTEGRITY
Description
Designation Rating Field
d Field Rating Field d
Recommende
5 The fossils within - this 4 Project design must - - Heritage This geological palaeontologically The integrity of the change to avoid all This geological This geological resources with formation was not sensitive formation formation is change to resource; Karoo formation was not formation was not qualities so assessed against potentially provide considered to be Very High Conserved in entirety KSGRP Geological Supergroup assessed against assessed against Grade I exceptional that aesthetic criteria significant excellent with both 20 and included in lithologies historic criteria as social criteria as they are of special as defined in scientific tangible and Conservation defined in Section defined in Section national Section 3(3) of the information and intangible fabric Management Plan 3(3) of the NHRA. 3(3) of the NHRA. significance. NHRA. are considered preserved. (CMP). rare heritage resources.
5 Project design must
- Burial grounds and 4 change to avoid the BGG-001 - - graves have Heritage Burial grounds and The integrity of resource completely and Burial grounds and Burial grounds and specific resources with graves were not burial grounds is resources must be graves were not graves were not connections to qualities so Burial / Burial Grounds & assessed against considered to be Very High included in CMP. assessed against assessed against communities or Grade I exceptional that grave Graves aesthetic criteria excellent with both 20 A Grave Relocation historic criteria as scientific criteria as groups for spiritual they are of special as defined in tangible and Process (GRP) may be defined in Section defined in Section reasons. The national Section 3(3) of the intangible fabric necessary should the BGG-002 3(3) of the NHRA. 3(3) of the NHRA. significance is significance. NHRA. preserved. project design not be universally changed. accepted.
2 1 1 0 The technical skill This resource - This resource was The information Resources under represented here represents a time Stone Age found out of potential of this general protection is commonly period which is materials were not context and, as General Isolated MSA resource is very Negligible in terms of NHRA Sufficiently recorded, no SA-001 Occurrence represented in commonly assessed against such, there is Protection IV flake limited, and does 1 sections 34 to 37 mitigation required diverse cultural represented in social criteria as limited information C not contribute to with Negligible landscapes, but is diverse defined in Section potential and the the value of the significance not common in this landscapes across 3(3) of the NHRA. original setting has object. region. South Africa. been lost.
8 Please note: this recommended mitigation refers to the minimum mitigation requirements as encapsulated in the NHRA. Project-specific mitigation measures are presented in Section 9.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Minimum Resource ID Type Description Recommended 8
Social Mitigation
Historic
Scientific
Aesthetic
INTEGRITY
Description
Designation Rating Field
d Field Rating Field d
Recommende
1 2 2 1 This heritage This heritage The technical skill The affiliation of 1 resource does not resource may Resources under represented here this structure is not The fabric of this offer uncommon present specific general protection is commonly clear and the resource is poorly General information value to certain Negligible in terms of NHRA Sufficiently recorded, no STE-001 Occurrence Foundations represented in resource preserved and Protection IV potential. The members of the 2 sections 34 to 37 mitigation required diverse cultural represents there is little C resource has been community but with Negligible landscapes, but features common meaning ascribed degraded and is otherwise does not significance this example is of in the cultural to the resource. common in the hold particular superior quality. landscape. region. social value 2
This heritage 3 1 2 2 resource may The fabric of the The technical skill This structure is an This resource Resources under present specific heritage resource represented here example of presents more general protection value to certain is fairly well General House in state of is commonly housing which is information Negligible in terms of NHRA Sufficiently recorded, no STE-002 Occurrence members of the preserved and Protection IV ruin represented in commonly potential than 2 sections 34 to 37 mitigation required community and there is limited C diverse cultural represented other examples with Negligible represents a encroachment. landscapes across across South common within the significance shared period The meaning is South Africa. Africa. region. within the evident. country’s past.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
6.2 Heritage Impact Assessment The assessment of potential impacts to heritage resources considers the aforementioned activities associated with the Project, specifically the construction and operation of the aforementioned infrastructure and agro-processing activities. The final proposed infrastructure layout is not available at this time. Digby Wells has therefore assumed that all heritage resources will be affected by the Project and have included mitigation measures to avoid or ameliorate these impacts. Impacts to the palaeontological resources are discussed in the specialist PIA report (refer to Appendix C) and are not repeated here. Table 6-2 provides summaries of the impacts to the heritage resources. The cultural heritage resources of the same type of CS have been grouped together for the purposes of the impact assessment. The SAHRA Minimum Standards recommend that heritage resources with negligible CS require no mitigation and their inclusion into an HIA report is considered to be sufficient in terms of recording these resources. Their inclusion into Table 5-3 and Figure 5-3 is considered sufficient to meet these requirements. To this effect, potential impacts posed to the isolated lithic SA-001 and historical built environment resources STE-001 and STE-002 are not considered in this section.
6.2.1 Direct impacts to Burial Grounds and Graves Potential direct impacts to the identified burial grounds and graves include damage to individual graves within the burial ground and damage to the burial ground as a whole, destruction of individual graves within the burial ground and the destruction of the burial ground as a whole. Destruction is anticipated where the burial ground is located within the infrastructure footprints and damage is to be expected where the burial ground is within proximity to the footprints, up to a distance of 50 m. Table 6-2 below presents a summary of the assessment of direct impacts to BGG-001 and BGG-002. Table 6-2: Summary of the potential direct impact to Burial Grounds and Graves
IMPACT DESCRIPTION: Burial grounds and graves
Dimension Rating Motivation
PRE-MITIGATION
Damage to or destruction of this Consequence: Significance: heritage resource will be Extremely Major – Duration Permanent (7) permanent and cannot be detrimental negative reversed. (-21) (-126)
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
IMPACT DESCRIPTION: Burial grounds and graves
Dimension Rating Motivation
These heritage resources have internationally-recognised Extent International (7) significance and, as such, their damage or destruction may have international implications.
Damage to or destruction of this Intensity x Extremely high - heritage resources is considered type of negative (-7) a major change to a resource impact with very high CS. Given the proposed activities within the Project Highly probable area and the location of these resources, it is Probability (6) highly likely that the burial grounds will be affected by the Project.
MITIGATION:
LEDA must alter the infrastructure design and layout to avoid these heritage resources and must include a 50 m 'no-go' buffer zone around the heritage resource. LEDA must draft and implement a CMP to consider these heritage resources and conserve the CS of the heritage resources. Should a change in the Project infrastructure layout not be feasible, LEDA must undertake a GRP, which will require permits issued by SAHRA in terms of Section 36 of the NHRA for those graves older than 60 years. This process must comply with Chapter IX and XI of the NHRA Regulations.
POST-MITIGATION Should the CMP be developed Beyond project life and implemented, the benefits Duration (6) will extend beyond the lifecycle
of the Project.
Consequence: The CMP will affect individual Highly Extent Local (3) heritage resources within the beneficial Significance: Project area. Moderate – (14) Implementation of the CMP will positive Intensity x be considered a minor change (84) type of High - positive (5) to a heritage resource of very impact high CS.
Should the CMP be implemented, it is most likely Highly probable Probability that the heritage resources will be impacted in a (6) positive way.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
6.3 Cumulative impacts on the cultural landscape Cumulative impacts occur from in-combination effects of various impacts on heritage resources acting within a host of processes that result in an incremental effect. The importance of identifying and assessing cumulative impacts is that the whole is often greater than the sum of its parts. This implies that the total effect of multiple stressors or change processes acting simultaneously on a system may be greater than the sum of their effects when acting in isolation. This Project in conjunction with other planned developments in line with the strategic development plans for the Limpopo Province requires consideration to identify the possible in-combination effects of various impacts to known heritage resources. The possible cumulative impacts of the Project are presented in Table 6-3. Table 6-3: Summary of potential cumulative impacts
Direction of Extent of Type Cumulative Impact Impact Impact
The construction of the proposed Project infrastructure
will add to the existing and proposed infrastructure in
the area and will contribute to the degradation of the sense-of-place of the cultural landscape. This is Additive, especially true in light of the additional proposed SEZ Negative Local Synergistic developments near Musina. Considering the greater development landscape, the effects from the various proposed developments will interact to produce a total greater effect on the cultural landscape and degradation thereof.
This Project, in conjunction with the additional SEZ
developments proposed near Musina will drastically Space reduce the space within which cultural heritage Negative Local Crowding resources may exist and be identified and will degrade the regional cultural heritage landscape.
The in situ conservation of some or all of the identified
heritage resources will conserve tangible markers of the historical landscape. This will be a positive Neutralizing Positive Local cumulative impact on the cultural landscape and may counter some of the degradation of the sense-of-place as described above.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
6.4 Low risks and unplanned events This section considers the potential risks to protected heritage resources, as well as the potential heritage risks that could arise for LEDA in terms of implementation of the Project. These two aspects are discussed separately. Section 5.2 describes the heritage resources identified during the pre-disturbance survey. This, however, is not an exhaustive list of all heritage resources within the Project area. If heritage resources are subsequently identified, and where LEDA knowingly does not take proactive management measures, potential risks to LEDA may include litigation in terms of Section 51 of the NHRA and social or reputational repercussions. Table 6-4 presents a summary of the primary risks that may arise for LEDA. Table 6-4: Identified heritage risks that may arise for LEDA
Description Primary Risk
Heritage resources with a high CS rating are inherently sensitive to any development in so far Negative Record of Decision (RoD) and/or that the continued survival of the resource could development restrictions issued by the LIHRA be threatened. In addition to this, certain and/or SAHRA in terms of Section 38(8) of the heritage resources are formally protected NHRA. thereby restricting various development activities.
Impacting on heritage resources formally and Fines generally protected by the NHRA without Penalties following due process. Seizure of Equipment Due process may include social consultations Compulsory Repair / Cease Work Orders and/or permit application processes to SAHRA and/or LIHRA. Imprisonment
In the event that additional heritage resources are identified during construction of the proposed infrastructure, potential risks to those heritage resources will need to be assessed. Table 6-5 provides an overview of these potential unplanned events, the subsequent impact that may occur and mitigation measures and management strategies to remove or reduce these risks.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Table 6-5: Identified unplanned events and associated impacts
Mitigation / Management / Unplanned event Potential impact Monitoring
Accidental damage to in situ Damage or destruction of historical built environment sites heritage resources generally during the implementation of the protected under Section 34 of
Project. the NHRA.
Accidental exposure of fossil bearing material implementation of the Project. Damage or destruction of Establish Project-specific heritage resources generally Chance Find Procedures Accidental exposure of in situ protected under Section 35 of (CFPs) and Fossil Finds archaeological material during the NHRA. Procedures (FFPs) as a the implementation of the condition of authorisation. Project. Refer to Section 9 for more Accidental exposure of in situ detailed recommendations. burial grounds or graves during the implementation of the Damage or destruction of Project. heritage resources generally protected under Section 36 of Accidental exposure of human the NHRA. remains during the construction phase of the Project.
Should sites be identified within the Project area, such sites must be included in the CMP.
Increased dust generated by Upon identification, immediate Negative changes to the status Project activities during the remedial action includes: quo and integrity of heritage construction and operational resources, specifically Rock Art, ■ Recording the Rock Art phase of the Project that could generally protected under sites baseline conditions; impact on previously Section 35 of the NHRA and unidentified heritage resources. ■ Include identified sites into a monitoring programme encapsulated in the CMP
7 Identified Heritage Impacts versus Socio-Economic Benefit This section provides a brief overview9 of the socio-economic context within with the Project will be situated. The site-specific study area includes parts of the Musina and Makhado Local
9 For a more detailed analysis of the socio-economic context and the positive and negative impacts of the Project, refer to the Social Impact Assessment undertaken in support of the EIA.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Municipalities. Both of these occur within the VDM. This section presents a summary of the information included in the Integrated Development Plans10 (IDPs) for all three municipalities. Information from Wazimap (2017) has been used to supplement the IDP data. These data were used because it realigns the 2011 Census data captured and presented by Statistics South Africa (2011) with new municipal boundaries used in the 2016 Municipal Elections (Open Up, 2017). This report uses the Census 2011 data as data from the 2016 Community Survey are not yet available at ward level. Using the Census 2011 data makes the data easier to compare. The 2011 census recorded 5 404 868 people living in the Limpopo Province (Statistics South Africa, 2011; Wazimap, 2017). This is approximately 10.44% of the South African population. VDM is the largest district (in terms of population), with 1 294 722 inhabitants. In terms of the local municipalities within the province, Makhado is the fifth largest in terms of population size (401 444 people) and Musina is the fifth smallest (with 104 564 inhabitants), out of twenty-two municipalities. Makhado and Musina are the largest and smallest local municipalities within the VDM respectively. Unemployment is a major challenge within the regional study area. Table 7-1 provides a summary of the relevant statistics. The trends across the regional study area are fairly consistent, as between 50% and 60% of the population are of economically active age (i.e. between the ages of 15 and 65) and the employment rate ranges from 14% to 16%. The employment rate in Musina is much higher, at 27.8%. Figure 7-1 below presents a breakdown of the employment status of the populations within the regional study area. In this figure, “not applicable” refers to members of the community who are not of economically-active age (i.e. those who are younger than 15 and aged 65 and older). Discouraged work seeker refers to those who are unemployed but are no longer seeking employment. Table 7-1: Summary of the employment statistics within the regional study area
Makhado Musina VDM Employment Statistics No. % No. % No. %
Total Population 401 444 - 104 654 - 1 294 722 -
Working Age (15-64) 207 721 51.70 60 769 58.10 664 507 51.30
Employed 67 754 16.90 29 143 27.80 189 361 14.60
Adapted from Statistics South Africa (2011) and Wazimap (2017)
10 Makhado (2018) and Musina (2018) Local Municipalities and VDM (2017)
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
100% 90% Employed 80% 70% Discouraged Work 60% Seeker 50% Unemployed 40% 30% Other not economically 20% active 10% Not Applicable 0% Musina Makhado VDM
Figure 7-1: Employment status within the regional study area
Adapted from Wazimap (2017) The Gross Value Added (GVA) of the mining industry grew by 1.2% in Limpopo in 2011 (Makhado Local Municipality, 2018). Conversely, the industry’s GVA declined by 9.3% in VDM and 10.1% in Makhado in this time. Within VDM, mining accounts for 10.2% of employment opportunities in the district (VDM, 2017). This is the fourth largest contributor to employment in VDM, behind community services, trade and finance. In Makhado in 2011, the community services sector was the largest contributor to employment, employing 27.45% of the workforce (Makhado Local Municipality, 2018). This was followed by the trade and agriculture sectors. During that year, the highest number of jobs lost occurred in the mining and agricultural industries. Mining and quarrying is a declining sector in Musina as well (Musina Local Municipality, 2018). Despite this, mining contributes 30% to the economy of Musina, second in contribution only to the agriculture, forestry and fishing sector. As per the Musina Local Municipality IDP (2018), the relative decline in the mining industry is due to a lack of technical skills to support the current mining operations. Despite this, the district and both local municipalities consider the mining industry a strength within their economic situations and a strategic goal (VDM, 2017; Makhado Local Municipality, 2018; Musina Local Municipality, 2018). The Project aims at investing in bulk into the Musina and Makhado municipalities and will direct create temporary and long-term employment opportunities for the skilled, semi-skilled and non-skilled workforces. The Project aims to provide support all along the mining and mineral beneficiation value chain and will directly contribute to the construction industry. There will be indirect benefits through knock-on effects which will increase employment opportunities in other sectors, such as transportation and accommodation industries. Based on the review of the applicable planning documents and the motivation above, the potential socio-economic benefits that may result from the Project and the SEZ development
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514 outweigh the identified impacts and risks to known heritage resources within the site-specific study area. This statement is supported by the following:
■ The infrastructure design layout is flexible and may be altered to allow the identified heritage resources to remain and be maintained in situ;
■ Alternatively, the identified impacts and risks can be managed through the proposed recommendations; and
■ The proposed SEZ Development will contribute significantly to the employment of people in an area where unemployment is a challenge.
8 Consultation The consultation process affords Interested and Affected Parties (I&APs) opportunities to engage in the EIA process. The objectives of the Stakeholder Engagement Process (SEP) include the following:
■ To ensure that I&APs are informed about the project;
■ To provide I&APs with an opportunity to engage and provide comment on the project;
■ To draw on local knowledge by identifying environmental and social concerns associated with the project;
■ To involve I&APs in identifying methods in which concerns can be addressed;
■ To verify that stakeholder comments have been accurately recorded; and
■ To comply with the legal requirements.
Delta BEC is undertaking the Public Participation Process (PPP), as a process separate to the heritage specialist assessment. Digby Wells did not undertake any formal consultation as part of this assessment. Should any I&APs submit comments in relevance to heritage resources during the SEP, these will be considered in the final EIA report. Site surveys can often present an opportunity for informal consultation with specific stakeholders (usually farm owners, managers and employees). This consultation can result in the identification of burial grounds and graves – importantly, these could include formal burial grounds or graves, sometimes with no visible surface markers – or in the identification of sacred sites or other places of importance, which may not otherwise be identified. No such informal consultation was undertaken during the pre-disturbance survey.
9 Recommendations To mitigate against the identified impacts against cultural and fossil heritage resources, Digby Wells recommends:
■ A suitably-qualified archaeologist must undertake a walk-down of the final Project layout, where such areas were not included in this assessment;
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
■ LEDA amends the infrastructure design where possible to avoid identified heritage resources of significance within the Project area and incorporate a no-go buffer zone of 50 m between the heritage resources and Project activities. Digby Wells acknowledges that it may not be feasible to avoid all the identified heritage resources;
■ Where identified heritage resources are avoided, LEDA must develop and implement a CMP to manage conserved heritage resource. The CMP must include any applicable mitigation measures, management strategies and proposed monitoring schedules and outline the roles and responsibilities of those involved. This document must be submitted to the HRAs for approval prior to implementation;
■ LEDA amends the Project design to avoid negative impacts to the built heritage resources and, where possible, conserve the resources through adaptive reuse of the structures. This will require a permit issued in terms of Section 34 of the NHRA and Chapter III of the NHRA Regulations;
■ Where this is not feasible or desirable, LEDA must complete a destruction permit application process in accordance with Section 34 of the NHRA and Chapter III of the NHRA Regulations;
■ Where burial grounds and graves will be impacted upon by the proposed infrastructure, LEDA must undertake a GRP in accordance with Section 36 of the NHRA and Chapter IX and XI of the NHRA Regulations;
■ Where archaeological sites will be impacted upon by the proposed infrastructure, LEDA must record the sites in detail in accordance with Section 35 of the NHRA and Chapter IV of the NHRA Regulations;
■ LEDA must identify rock art sites that may be affected by additional dust or other emissions generated by the Project and record these sites in sufficient detail to develop an accurate baseline that can be used to monitor changes to the integrity of the rock art. LEDA must develop and implement a monitoring programme to identify and manage changes to the rock art;
■ Where rock art sites are identified within the Project area, such sites must be included in the Project-specific CMP;
■ A project-specific CFP must be developed and approved by the HRAs prior to the commencement of the construction of Project-related infrastructure; and
■ The project-specific FFP must be approved prior to the commencement of the construction phase of the Project (refer to Appendix A of the PIA report).
10 Conclusion The aim of the HRM process was to comply with regulatory requirements contained within Section 38 of the NHRA through the following:
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
■ Defining the cultural landscape within which the Project is situated;
■ Identifying, as far as is feasible, heritage resources that may be impacted upon by the project as well as define the CS;
■ Assessing the possible impacts to the identified heritage resources;
■ Considering the socio-economic benefits of the Project; and
■ Providing feasible mitigation and management measures to avoid, remove or reduce perceived impacts and risks. These objectives were met as presented in Sections 5 through 9 above. Based on the understanding of the Project while considering the results of this assessment, Digby Wells does not object to the Project where the provided cultural and fossil heritage specific recommendations are adopted.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
11 Works Cited Behrens, J. & Swanepoel, N., 2008. Historical archaeologies of southern Africa: precedents and prospects. In: N. Swanepoel, A. Esterhuysen & P. Bonner, eds. Five Hundred Years Rediscovered: South African precedents and prospects. Johannesburg: Wits University Press, pp. 23-39. Biemond, W. M., 2014. The Iron Age Sequence around a Limpopo River floodplain on Basinghall Farm, Tuli Block, Botswana, during the second Millenium AD, Unpublished MA dissertation: University of South Africa. Clark, J., 1982. The cultures of the Middle Palaeolithic/Middle Stone Age. In: J. Clark, ed. The Cambridge History of Africa, Volume 1: From the Earliest Times to c. 500 BC. Cambridge: Cambridge University Press, pp. 248-341. Deacon, H. & Deacon, J., 1999. Human Beginnings in South Africa. Cape Town: David Phillip. Delius, P., Maggs, T. & Schoeman, A., 2014. Forgotten World: The Stone-walled Settlements of the Mpumalanga Escarpment. First ed. Johannesburg: Wits University Press. Esterhuysen, A. & Smith, J., 2007. Stories in Stone. In: P. Delius, ed. Mpumalanga: History and Heritage: reclaiming the past, defining the future. Pietermatiztburg: University of KwaZulu-Natal Press, pp. 41-67. Genealogical Society of South Africa, 2011. Google Earth Cemetery Initiative. Google Earth Database: Genealogical Society of South Africa Database. Huffman, T., 2007. The Handbook to the Iron Age: The Archaeology of Pre-Colonial Farming Societies in Southern Africa. Pietermaritzburg: Univerity of KwaZulu-Natal Press. Huffman, T. & Van der Walt, J., 2011. A Field Study prepared for Environmental Resources Management, Sasol Technology, Archaeological Resources Management: Unpublished report prepared for SRK Consulting and Sustainable Enviromental Solutions. Makhado Local Municipality, 2018. Makhado Municipality Integrated Development Plan: 2018-2019 IDP Review, Makhado: Unpublished municipality policy document. Mitchell, P., 2002. The Archaeology of Southern Africa. Cambridge: Cambridge University Press. Mott MacDonald, 2015. Musina Special Economic Zone License Application for Designation - Feasibility Study, Mott MacDonald PDNA: Unpublished report prepared for LEDA and DTI. Mucina, L. & Rutherford, M. C., 2010. The Vegetation of South Africa, Lesotho and Swaziland. CD Version ed. Pretoria: Strelitzia: South African National Biodiversity Institute. Musina Local Municipality, 2018. Musina Local Municipality: 2018/19 Final Draft Integrated Development Plan, Musina: Unpublished municipality policy document. Nel, J., 2012. Phase 2 Archaeological Assessment: Mitigation for Boikarabelo Coal Mine, Digby Wells Environmental: Unpublished report.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Open Up, 2017. Wazimap updated with 2016 Municipal Election Results and new municipalities. [Online] Available at: https://openup.org.za/articles/wazimap-2016-update.html [Accessed 26 April 2019]. Roodt, F., 2011. Phase 1 Heritage Impact Assessment: Eskom Power Line, Paradise Substation to the proposed Makhado Colliery, RR Cultural Heritage Resource Consultants: Unpublished report prepared for Jacana Environmental. Case ID 65. Roodt, F. E. & Roodt, F., 2014. Phase 1 Heritage Resources Scoping Report: Tshivhase Nature Reserve, Vondo Dam, Limpopo Province, SHASA Heritage Consultants CC: Unpublished report prepared for Polygon Environmental Planning. SAHRA, 2013. SAHRIS Fossil Heritage Layer Browser. [Online] Available at: https://www.sahra.org.za/sahris/fossil-heritage-layer-browser [Accessed 26 April 2019]. Schapera, I., 1953. The Tswana. London: International African Institute Press. Silidi, M. A. & Matenga, E., 2013. Heritage Impact Assessment for the proposed Greater Soutpansberg Mopane Project, Mbofho Consulting and Project Managers: Unpublished report prepared for Jacana Environmentals CC and Coal of Africa Limited. Case ID 4577. Smuts, K., 2018. Heritage Impact Assessment in terms of Section 38(8) of the NHRA for a Proposed New Mutsho Power Project near Makhado, CTS Heritage: Unpublished report in association with Savannah Environmental. Case ID 11558. Statistics South Africa, 2011. Statistics by Place. [Online] Available at: http://www.statssa.gov.za/?page_id=964 [Accessed 26 April 2019]. Swanepoel, N., Esterhuysen, A. B. & Bonner, P., 2008. Five Hundred Years Rediscovered: Southern African Precedents and Prospects. Johannesburg: Wits University Press. VDM, 2017. Vhembe District Municipality: 2017/18-2021/22 IDP, Thohoyandou: Unpublished municipality policy document. Wazimap, 2017. Wazimap. [Online] Available at: https://wazimap.co.za/ [Accessed 26 April 2019]. Winter, S. & Baumann, N., 2005. Guidelines for involving heritage specialists in EIA processes: first edition.CSIR Report No ENV-S-C 2005 053 E, Cape Town: Provincial Government of the Western Cape, Department of Environmental Affairs & Development Planning. WITS, 2010. Archaeological Site Database, Johannesburg: Department of Geography, Archaeology and Environmental Science.
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Appendix A: Specialist CV
Miss Shannon Hardwick Heritage Resources Management Consultant Social and Heritage Services Division Digby Wells Environmental
1 Education
Date Degree(s) or Diploma(s) obtained Institution 2013 MSc (Archaeology) University of the Witwatersrand 2010 BSc (Honours) (Archaeology) University of the Witwatersrand 2009 BSc University of the Witwatersrand 2006 Matric Rand Park High School
2 Language Skills
Language Written Spoken
English Excellent Excellent
Afrikaans Fair Basic
3 Employment
Period Company Title/position
2017 to present Digby Wells Environmental Junior Heritage Resources Management Consultant
2016-2017 Tarsus Academy Facilitator
2011-2016 University of the Witwatersrand Teaching Assistant
2011 University of the Witwatersrand Collections Assistant
______Digby Wells and Associates (South Africa) (Pty) Ltd. Co. Reg. No. 2010/008577/07. Turnberry Office Park, 48 Grosvenor Road, Bryanston, 2191. Private Bag X10046, Randburg, 2125, South Africa Tel: +27 11 789 9495, Fax: +27 11 069 6801, [email protected], www.digbywells.com
______Directors: GE Trusler (C.E.O), LF Stevens, J Leaver (Chairman)*, NA Mehlomakulu*, DJ Otto
*Non-Executive ______
4 Experience I joined the Digby Wells in April 2017 as an archaeologist and a Heritage Resources Management intern in the Social and Heritage Services Division and have most recently been promoted to a Junior Consultant. I received my Master of Science (MSc) degree in Archaeology from the University of the Witwatersrand in 2013, specialising in archaeobotany and historical archaeology. I have fieldwork experience in historical archaeology as well as in Stone Age archaeology in South Africa; since joining Digby Wells, this has been expanded to include pre-disturbance surveys across South Africa and fieldwork in Malawi. Since joining Digby Wells, I have gained generalist experience through the compilation of various heritage assessment reports in South Africa, Malawi and Mali and Section 34 Permit Applications. I have also obtained experience in compiling socio-economic documents, including a Community Health, Safety and Security Management Plan (CHSSMP) and social baselines and data analysis in South Africa, Malawi, Mali and Sierra Leone.
5 Project Experience My project experience is listed in the table below.
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Project / Experience Project Title Name of Client Project Location Date: Description
Environmental Authorisation for the Ermelo, Mpumalanga Heritage Impact Dagsoom Coal Mining Project near Ermelo, Dagsoom Coal Mining (Pty) Ltd April 2019 Ongoing Province Assessment Mpumalanga Province
Regional Tailings Storage Facility Heritage Section 34 Permit Ergo Mining (Pty) Ltd Randfontein, Gauteng April 2019 Ongoing Mitigations Application Process
Weltervreden Mine Environmental Heritage Impact Authorisation, Water Use Licence and Mbuyelo Group (Pty) Ltd Belfast, Mpumalanga April 2019 Ongoing Assessment Mining Right Application Project
Environmental Authorisation for the Lephalale, Limpopo Notification of Intent to proposed Lephalale Pipeline Project, MDT Environmental (Pty) Ltd April 2019 Ongoing Province Develop Limpopo Province
Heritage Site Heritage Resources Management Process Exxaro Coal Mpumalanga (Pty) Kriel, Mpumalanga February Ongoing Management Plan Update for the Exxaro Matla Mine Ltd Province 2019 Update
Environmental Authorisation for the Vhembe District proposed Musina-Makhado Special Limpopo Economic February Heritage Impact Municipality, Limpopo Ongoing Economic Zone Development Project, Development Agency 2019 Assessment Province Limpopo Province
Phalombe District, February Heritage Impact Songwe Hills Rare Earth Elements Project Mkango Resources Limited Ongoing Malawi 2019 Assessment
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Project / Experience Project Title Name of Client Project Location Date: Description
Anker Coal and Mineral Elandsfontein Colliery Burial Grounds and Clewer, Emalahleni, November December Holdings SA (Pty) Ltd Site Inspection Graves Chance Finds Mpumalanga Province 2018 2018 Elandsfontein Colliery (Pty) Ltd
Environmental Authorisation Process to Secunda, Mpumalanga November Notification of Intent to Decommission a Conveyor Belt Servitude, Sasol Mining (Pty) Ltd Ongoing Province 2018 Develop Road and Quarry at Twistdraai East Colliery
Environmental and Social Impact October Heritage Impact Assessment for the Bougouni Lithium Future Minerals S.A.R.L. Bougouni, Mali Ongoing 2018 Assessment Project, Mali
Environmental Authorisation for the Nomalanga Property Holdings October Heritage Impact Nomalanga Estates Expansion Project, Greytown. KwaZulu-Natal Ongoing (Pty) Ltd 2018 Assessment KwaZulu-Natal
Environmental Authorisation for the Temo Lephalale, Limpopo August Heritage Impact Mine proposed Rail, Road and Pipeline Temo Coal Mining (Pty) Ltd Ongoing Province 2018 Assessment Development, Limpopo Province
Kibali Sector, Democratic December Resettlement Action Plan Gorumbwa RAP Audit Randgold Resources Limited July 2018 Republic of the Congo 2018 Audit
Sasol Sigma Defunct Colliery Surface Sasolburg, Free State November Notification of Intent to Mitigation Project: Proposed Rover Sasol Mining (Pty) Ltd June 2018 Province 2018 Develop Diversion and Flood Protection Berms
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Project / Experience Project Title Name of Client Project Location Date: Description Basic Assessment and Regulation 31 Amendment / Consolidation for Sigma Sasolburg, Free State Notification of Intent to Sasol Mining (Pty) Ltd April 2018 Ongoing Colliery: Mooikraal and Sigma Colliery: 3 Province Develop Shaft
Heritage Basic Sasol Mining Sigma Colliery Ash Backfilling Sasolburg, Free State Sasol Mining (Pty) Ltd April 2018 July 2018 Assessment Report Project, Sasolburg, Free State Province Province Update
Constructed Landfill Site for the Sierra Southern Province, Sierra Social Impact Rutile Limited Mining Operation, Southern Sierra Rutile Limited April 2018 May 2019 Leone Assessment Province, Sierra Leone
Environmental Impact Assessment for the South32 SA Coal Holdings (Pty) Ogies, Mpumalanga Notification of Intent to Klipspruit Colliery Water Treatment Plant March 2018 Ongoing Ltd Province Develop; Social baseline and associated pipeline, Mpumalanga Proposed construction of a Water Treatment Plant and associated infrastructure for the Newcastle, KwaZulu- February Heritage Impact Eskom Holdings SOC Limited Ongoing Treatment of Mine-Affected Water at the Natal Province 2018 Assessment Kilbarchan Colliery
Exxaro Coal Mpumalanga (Pty) Belfast, Mpumalanga February Section 34 Permit Belfast Implementation Project Ongoing Ltd Province 2018 Application
GCS Water and Environmental Newcastle, KwaZulu- January Heritage Impact Newcastle Landfill Project March 2019 Consultants Natal 2018 Assessment
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Project / Experience Project Title Name of Client Project Location Date: Description NHRA Section 34 Permit Application process for the Davin and Queens Court Johannesburg, Gauteng January Section 34 Permit IDC Architects May 2018 Buildings on Erf 173 and 174, West Province 2018 Application Process Germiston, Gauteng Province
Basic Assessment and Environmental Management Plan for the Proposed pipeline HCI Coal (Pty) Ltd Ogies, Mpumalanga November February Heritage Basic from the Mbali Colliery to the Tweefontein Mbali Colliery Province 2017 2018 Assessment Report Water Reclamation Plant, Mpumalanga Province
The South African Radio Astronomy Heritage Impact The South African Observatory Square Kilometre Array Carnarvon, Northern November Assessment; Radio Astronomy July 2018 Heritage Impact Assessment and Cape Province 2017 Conservation Observatory (SARAO) Conservation Management Plan Project Management Plan
Heritage Impact
Environmental Impact Assessment for the Assessment Rustenburg, North West November proposed Future Developments within the Sun International (Pty) Ltd Ongoing Conservation Province 2017 Sun City Resort Complex Management Plan Social Baseline
Environmental Fatal Flaw Analysis for the Waterberg, Limpopo November November Mr van den Bergh Fatal Flaw Analysis Mabula Filling Station Province 2017 2017
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Project / Experience Project Title Name of Client Project Location Date: Description
Environmental Impact Assessment for the October Notification of Intent to Blyvoor Gold Mining Project near Blyvoor Gold Capital (Pty) Ltd Carletonville, Gauteng Ongoing 2017 Develop; Social Baseline Carletonville, Gauteng Province
Heritage Resources Management Process Exxaro Coal Mpumalanga (Pty) Kriel, Mpumalanga August October Heritage Impact for the Exxaro Matla Mine Ltd Province 2017 2018 Assessment Community Health, Liwonde Additional Studies Mota-Engil Africa Liwonde, Malawi June 2017 June 2018 Safety and Security Management Plan
Environmental Impact Assessment for the December Heritage Impact Sibanye-Stillwater Randfontein, Gauteng June 2017 Millsite TSF Complex 2017 Assessment Heritage Resources Management Process for the Portion 296 of the farm Zuurfontein Ekurhuleni Notification of Intent to Shuma Africa Projects (Pty) Ltd May 2017 June 2017 33 IR Proposed Residential Establishment (Johannesburg), Gauteng Develop Project
NHRA Section 35 Archaeological Rustenburg, North West August Archaeological Phase 2 Investigations, Lanxess Chrome Mine, Lanxess Chrome Mine (Pty) Ltd March 2017 Province 2017 Mitigation North-West Province
Pre-Feasibility Study; Environmental and Social Input for the Pre- January October Birimium Gold Bougouni, Mali Heritage Impact Feasibility Study 2017 2018 Assessment
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6 Professional Registration
Position Professional Body Registration Number
Member Association of Southern African Professional 451 Archaeologists (ASAPA)
Member International Council on Monuments and Sites (ICOMOS) 38048
7 Publications Esterhuysen, A.B. & Hardwick, S.K. 2017. Plant remains recovered from the 1854 siege of the Kekana Ndebele, Historic Cave, Makapan Valley, South Africa. Journal of Ethnobiology 37(1): 97-119.
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Mr. Justin du Piesanie Divisional Manager: Social and Heritage Services Social and Heritage Services Department Digby Wells Environmental
1 Education
Date Degree(s) or Diploma(s) obtained Institution
2015 Continued Professional Development, Intermediate PM.Ideas: A division of the Project Management Course Mindset Group
2013 Continued Professional Development Programme, University of Cape Town Architectural and Urban Conservation: Researching and Assessing Local Environments
2008 MSc University of the Witwatersrand
2005 BA (Honours) (Archaeology) University of the Witwatersrand
2004 BA University of the Witwatersrand
2001 Matric Norkem Park High School
2 Language Skills
Language Written Spoken
English Excellent Excellent
Afrikaans Proficient Good
______Digby Wells and Associates (South Africa) (Pty) Ltd. Co. Reg. No. 2010/008577/07. Turnberry Office Park, 48 Grosvenor Road, B ryanston, 2191. Private Bag X10046, Randburg, 2125, South Africa Tel: +27 11 789 9495, Fax: +27 11 069 6801, [email protected], www.digbywells.com
______Directors: GE Trusler (C.E.O), GB Beringer, LF Koeslag, J Leaver* (Chairperson), NA Mehlomakulu, MJ Morifi*, DJ Otto, RA Williams
*Non-Executive ______
3 Employment
Period Company Title/position
2018 to present Digby Wells Environmental Divisional Manager: Social and Heritage Services
2016-2018 Digby Wells Environmental Unit Manager: Heritage Resources Management
2011-2016 Digby Wells Environmental Heritage Management Consultant: Archaeologist
2009-2011 University of the Witwatersrand Archaeology Collections Manager
2009-2011 Independent Archaeologist
2006-2007 Maropeng & Sterkfontein Caves UNESCO Tour guide World Heritage Site
4 Experience I joined the company in August 2011 as an archaeologist and was subsequently made manager of the Heritage Unit and subsequently the Divisional Manager for Social and Heritage Services in 2016 and 2018 respectively. I obtained my Master of Science (MSc) degree in Archaeology from the University of the Witwatersrand in 2008, specialising in the Southern African Iron Age. I further attended courses in architectural and urban conservation through the University of Cape Town’s Faculty of Engineering and the Built Environment Continuing Professional Development Programme in 2013. I am a professional member of the Association of Southern African Professional Archaeologists (ASAPA), and accredited by the association’s Cultural Resources Management (CRM) section. I am also a member of the International Council on Monuments and Sites (ICOMOS), an advisory body to the UNESCO World Heritage Convention. I have over 10 years combined experience in HRM in South Africa, including heritage assessments, archaeological mitigation, grave relocation, and NHRA Section 34 application processes. I gained further generalist experience since my appointment at Digby Wells in Botswana, Burkina Faso, Cameroon, the Democratic Republic of Congo, Liberia, Malawi, Mali, Senegal and Tanzania on projects that have required compliance with IFC requirements such as Performance Standard 8: Cultural Heritage. Furthermore, I have acted as a technical expert reviewer of HRM projects undertaken in Cameroon and Senegal. As Divisional Manager for Social and Heritage Services at Digby Wells Environmental, I manage several large capital Projects and multidisciplinary teams placing me in the best position to identify and exploit points of integration between the HRM process and greater social landscape. This approach to HRM, as an integrated discipline, is grounded in international HRM principles and standards that has allowed me to provide comprehensive,
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project-specific solutions that promote ethical heritage management and assist in achieving the strategic objectives of our clients, as well as maintain or enhance Cultural Significance of the relevant cultural heritage resources.
5 Project Experience Please see the following table for relevant project experience:
PROJECT LOCATION DATES PROJECT TYPE CLIENT
Westonaria, Section 34 Ergo RTSF Section 34 Gauteng, 2019 - Destruction Permit Ergo (Pty) Ltd Process South Africa Applications
Pilanesberg, Heritage Impact North-West Assessment and Sun City EIA and CMP 2018 - Sun International Province, Conservation South Africa Management Plan
Heritage Impact Kriel, Assessment and Exxaro Coal Mpumalanga (Pty) Exxaro Matla HRM Mpumalanga, 2017 - Conservation Ltd South Africa Management Plan
Belfast, Exxaro Coal Mpumalanga (Pty) Exxaro Belfast GRP Mpumalanga, 2013 - Grave Relocation Ltd South Africa
KwaZulu- Eskom Northern KZN Heritage Impact Natal, South 2016 2018 ILISO Consulting Strengthening Assessment Africa
Lephalale, Limpopo Thabametsi GRP 2017 2018 Grave Relocation Exxaro Resources Ltd Province, South Africa
Carnarvon, Heritage Impact Northern Assessment and SKA HIA and CMP 2017 2018 SARAO Cape, South Conservation Africa Management Plan Lephalale, Grootegeluk Watching Limpopo 2017 2017 Watching Brief Exxaro Resources Ltd Brief Province, South Africa Kriel, Mpumalanga Heritage Site Exxaro Coal Mpumalanga (Pty) Matla HSMP 2017 2017 Province, Management Plan Ltd South Africa
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PROJECT LOCATION DATES PROJECT TYPE CLIENT Lephalale, Ledjadja Coal Borrow Limpopo Heritage Basic 2017 2017 Ledjadja Coal (Pty) Ltd Pits Province, Assessment South Africa
Exxaro Belfast Belfast, Palaeontological Exxaro Coal Mpumalanga (Pty) Implementation Project Mpumalanga, 2017 2017 Impact Assessment Ltd PIA South Africa
Rustenburg, Lanxess Chrome Mine North West Archaeological 2017 2017 Phase 2 Excavations Lanxess Chrome Mine (Pty) Ltd Province, Mitigation South Africa
KwaZulu- Tharisa Apollo EIA Heritage Impact Natal, South 2017 2017 GCS (Pty) Ltd Project Assessment Africa
Germiston, Section 34 Queen Street Section Johannesburg, 2017 2017 Destruction Permit IDC Architects 34 Process Gauteng, Applications South Africa
Goulamina, Heritage Impact Goulamina EIA Project Sikasso 2017 2017 Birimian Limited Assessment Region, Mali
Ekurhuleni, Zuurfontein Residential Notification of Intent Gauteng, 2017 2017 Shuma Africa Projects Establishment Project to Develop South Africa Orientale Kibali Grave Relocation Province, Training and Democratic 2017 2017 Grave Relocation Randgold Resources Limited Implementation Republic of Congo Heritage Impact Massawa EIA Senegal 2016 2017 Assessment and Randgold Resources Limited Technical Reviewer
Welkom, Free Heritage Impact Beatrix EIA and EMP State, South 2016 2017 Sibanye Gold Ltd Assessment Africa
Pilanesberg, Notification of Intent North-West to Develop and Sun City Chair Lift 2016 2017 Sun International Province, Heritage Basic South Africa Assessment
Hendrina, Hendrina Underground Heritage Impact Mpumalanga, 2016 2017 Umcebo Mining (Pty) Ltd Coal Mine EIA Assessment South Africa
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PROJECT LOCATION DATES PROJECT TYPE CLIENT
Clewer, Elandsfontein EMP Heritage Impact Mpumalanga, 2016 2017 Anker Coal Update Assessment South Africa
Limpopo Groningen and Heritage Basic Rustenburg Platinum Mines Province, 2016 2016 Inhambane PRA Assessment Limited South Africa
Springs, Heritage Impact Palmietkuilen MRA Gauteng, 2016 2016 Canyon Resources (Pty) Ltd Assessment South Africa
Copper Sunset Sand Free State, Heritage Basic 2016 2016 Copper Sunset Sand (Pty) Ltd Mining S.102 South Africa Assessment
Springs, Notification of Intent Grootvlei MRA Gauteng, 2016 2016 Ergo (Pty) Ltd to Develop South Africa
Mpumalanga, Palaeontological Lambda EMP 2016 2016 Eskom Holdings SOC Limited South Africa Impact Assessment Newcastle, Kilbarchan Basic KwaZulu- Heritage Basic 2016 2016 Eskom Holdings SOC Limited Assessment and EMP Natal, South Assessment Africa Lephalale, Grootegeluk Limpopo Notification of Intent 2016 2016 Exxaro Amendment Province, to Develop South Africa
Pretoria, Garsfontein Township Notification of Intent Gauteng, 2016 2016 Leungo Construction Enterprises Development to Develop South Africa Johannesburg, Louis Botha Phase 2 Gauteng, 2016 2016 Phase 2 Excavations Royal Haskoning DHV South Africa Pilanesberg, Sun City Heritage North-West 2016 2016 Phase 2 Mapping Sun International Mapping Province, South Africa Heritage Impact Gino’s Building Section Johannesburg, Assessment and 34 Destruction Permit Gauteng, 2015 2016 Section 34 Bigen Africa Services (Pty) Ltd Application South Africa Destruction Permit Application
Heritage Impact Johannesburg, EDC Block Assessment and Gauteng, 2015 2016 Bigen Africa Services (Pty) Ltd Refurbishment Project Section 34 Permit South Africa Application
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PROJECT LOCATION DATES PROJECT TYPE CLIENT Steenbokpan, Namane IPP and Limpopo Heritage Impact 2015 2016 Namane Resources (Pty) Ltd Transmission Line EIA Province, Assessment South Africa
Steenbokpan, Temo Coal Road Limpopo Heritage Impact Diversion and Rail Loop 2015 2016 Namane Resources (Pty) Ltd Province, Assessment EIA South Africa
Gauteng, Heritage Impact Sibanye WRTRP 2014 2016 Sibanye South Africa Assessment
NTEM Iron Ore Mine Cameroon 2014 2016 Technical Review IMIC plc and Pipeline Project
NLGM Constructed Heritage Impact Liberia 2015 2015 Aureus Mining Wetlands Project Assessment ERPM Section 34 Johannesburg, Section 34 Destruction Permits Gauteng, 2015 2015 Destruction Permit Ergo (Pty) Ltd Applications South Africa Applications
Heritage Impact JMEP II EIA Botswana 2015 2015 Jindal Assessment
Bronkhorstspr Heritage Impact Oakleaf ESIA Project uit, Gauteng, 2014 2015 Oakleaf Investment Holdings Assessment South Africa
Kriel, Heritage Impact Imvula Project Mpumalanga, 2014 2015 Ixia Coal Assessment South Africa
Mokopane, VMIC Vanadium EIA Heritage Impact Limpopo, 2014 2015 VM Investment Company Project Assessment South Africa
Steelpoort, Everest North Mining Heritage Impact Mpumalanga, 2012 2015 Aquarius Resources Project Assessment South Africa
Orientale Province, Nzoro 2 Hydro Power Democratic 2014 2014 Social consultation Randgold Resources Limited Project Republic of Congo
Springs, Eastern Basin AMD Heritage Impact Gauteng, 2014 2014 AECOM Project Assessment South Africa
Soweto, Soweto Cluster Heritage Impact Gauteng, 2014 2014 Ergo (Pty) Ltd Reclamation Project Assessment South Africa
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PROJECT LOCATION DATES PROJECT TYPE CLIENT
Ogies, Heritage Impact Klipspruit South Project Mpumalanga, 2014 2014 BHP Billiton Assessment South Africa
Ogies, Klipspruit Extension: Heritage Impact Mpumalanga, 2014 2014 BHP Billiton Weltevreden Project Assessment South Africa
Ergo Rondebult Johannesburg, Heritage Basic Pipeline Basic 2014 2014 Ergo (Pty) Ltd South Africa Assessment Assessment
Orientale Province, Kibali ESIA Update Heritage Impact Democratic 2014 2014 Randgold Resources Limited Project Assessment Republic of Congo
Westonaria, GoldOne EMP Gauteng, 2014 2014 Gap analysis Gold One International Consolidation South Africa
Wakkerstroom Palaeontological Yzermite PIA , Mpumalanga, 2014 2014 EcoPartners Impact Assessment South Africa
Sasolburg, Sasol Mooikraal Basic Heritage Basic Free State, 2014 2014 Sasol Mining Assessment Assessment South Africa
Johannesburg, Rea Vaya Phase II C Heritage Impact Gauteng, 2014 2014 ILISO Consulting Project Assessment South Africa
New Liberty Gold Liberia 2013 2014 Grave Relocation Aureus Mining Project
Putu Iron Ore Mine Petroken, Heritage Impact 2013 2014 Atkins Limited Project Liberia Assessment
Secunda, Notification of Intent Sasol Twistdraai Project Mpumalanga, 2013 2014 ERM Southern Africa to Develop South Africa
Orientale Province, Kibali Gold Hydro- Heritage Impact Democratic 2012 2014 Randgold Resources Limited Power Project Assessment Republic of Congo
SEGA Gold Mining Burkina Faso 2013 2013 Technical Reviewer Cluff Gold PLC Project
Breyton, Consbrey and Harwar Heritage Impact Mpumalanga, 2013 2013 Msobo Collieries Project Assessment South Africa
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PROJECT LOCATION DATES PROJECT TYPE CLIENT Falea Uranium Mine Environmental Falea, Mali 2013 2013 Heritage Scoping Rockgate Capital Assessment
Daleside Acetylene Gas Gauteng, Heritage Impact 2013 2013 ERM Southern Africa Production Facility South Africa Assessment
SEGA Gold Mining Socio Economic and Burkina Faso 2012 2013 Cluff Gold PLC Project Asset Survey
Orientale Province, Kibali Gold Project Democratic 2011 2013 Grave Relocation Randgold Resources Limited Grave Relocation Plan Republic of Congo
Steelpoort, Everest North Mining Heritage Impact Mpumalanga, 2012 2012 Aquarius Resources Project Assessment South Africa Environmental Authorisation for the Gauteng, Heritage Impact 2012 2012 Gold One International Gold One Geluksdal South Africa Assessment TSF and Pipeline Mokopane, Platreef Burial Grounds Limpopo Burial Grounds and 2012 2012 Platreef Resources and Graves Survey Province, Graves Survey South Africa
Limpopo Resgen Boikarabelo Province, 2012 2012 Phase 2 Excavations Resources Generation Coal Mine South Africa Burgersfort, Bokoni Platinum Road Limpopo 2012 2012 Watching Brief Bokoni Platinum Mine Watching Brief Province, South Africa Kwa-Zulu Transnet NMPP Line Natal, South 2010 2010 Heritage survey Umlando Consultants Africa
Archaeological Impact Johannesburg, Archaeological Assessment – Gauteng, 2010 2010 ARM Impact Assessment Witpoortjie Project South Africa Der Brochen Steelpoort, Archaeological Mpumalanga, 2010 2010 Phase 2 Excavations Heritage Contracts Unit Excavations South Africa
De Brochen and Steelpoort, Site Recording: Booysendal Mpumalanga, 2010 2010 Heritage Contracts Unit Mapping Archaeology Project South Africa
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PROJECT LOCATION DATES PROJECT TYPE CLIENT Eskom Thohoyandou Limpopo Electricity Master Province, 2010 2010 Heritage Statement Strategic Environmental Focus Network South Africa
North-West Batlhako Mine Province, 2010 2010 Phase 2 Mapping Heritage Contracts Unit Expansion South Africa Shoshanguve, Wenzelrust Excavations Gauteng, 2009 2009 Phase 2 Excavations Heritage Contracts Unit South Africa University of the Parys, Free Witwatersrand Parys State, South 2009 2009 Phase 2 Mapping University of the Witwatersrand LIA Shelter Project Africa
Archaeological Johannesburg, Assessment of Heritage Basic Gauteng, 2008 2008 ARM Modderfontein AH Assessment South Africa Holdings Thabazimbi, Heritage Assessment of Limpopo Heritage Impact 2008 2008 Rhino Mines Rhino Mines Province, Assessment South Africa Thabazimbi, Limpopo Archaeological Cronimet Project 2008 2008 Cronimet Province, surveys South Africa
Limpopo Eskom Thohoyandou Province, 2008 2008 Heritage Statement Eskom SEA Project South Africa
Witbank Dam Witbank, Archaeological Archaeological Impact Mpumalanga, 2007 2007 ARM survey Assessment South Africa
Sun City, Pilanesberg, Sun City Archaeological Site Recording: North West 2006 2006 Sun International Site Mapping Mapping Province, South Africa
Meyersdal, Klipriviersberg Archaeological Gauteng, 2005 2006 ARM Archaeological Survey surveys South Africa
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6 Professional Registrations
Position Professional Body Registration Number
Member Association for Southern African Professional 270 Archaeologists (ASAPA); ASAPA Cultural Resources Management (CRM) section
Member International Council on Monuments and Sites 14274 (ICOMOS)
Member Society for Africanist Archaeologists (SAfA) N/A
Member International Association of Impact Assessors 5494 (IAIA) South Africa
7 Publications Huffman, T.N. & du Piesanie, J.J. 2011. Khami and the Venda in the Mapungubwe Landscape. Journal of African Archaeology 9(2): 189-206 du Piesanie, J.J., 2017. Book Review: African Cultural Heritage Conservation and Management. South African Archaeological Bulletin 72(205)
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Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514
Appendix B: HRM Methodology
Cultural Significance, Field Rating and Impact Assessment
Methodology Statement
Project Number: ZZZ9999
Prepared for: Internal Document
June 2019
______Digby Wells and Associates (South Africa) (Pty) Ltd Co. Reg. No. 2010/008577/07. Turnberry Office Park, 48 Grosvenor Road, Bryanston, 2191. Private Bag X10046, Randburg, 2125, South Africa Tel: +27 11 789 9495, Fax: +27 11 069 6801, [email protected], www.digbywells.com ______Directors: GE Trusler (C.E.O), LF Stevens, J Leaver (Chairman)*, NA Mehlomakulu*, DJ Otto *Non-Executive ______
This document has been prepared by Digby Wells Environmental.
Report Type: Methodology Statement
Project Name: Cultural Significance, Field Rating and Impact Assessment
Project Code: ZZZ9999
Revision History
Name Responsibility Version Date
Ver. 1 May 2014
Johan Nel HRM Unit Manager Ver. 2 October 2014 ASAPA Member 095 Ver. 3 May 2015
Ver. 4 January 2016
Justin du Piesanie Divisional Manager: Social Ver. 5 June 2016 ASAPA Member 270 and Heritage Services Ver. 6 June 2019
This report is provided solely for the purposes set out in it and may not, in whole or in part, be used for any other purpose without Digby Wells Environmental prior written consent.
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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999
TABLE OF CONTENTS
1 Introduction ...... 1
2 Evaluation of Cultural Significance and Field Ratings ...... 1
2.1 Cultural Significance Determination ...... 1 2.2 Field Rating Determination ...... 2 3 Impact Assessment Methodology ...... 4
3.1 Categorising Impacts to Cultural Heritage...... 6 3.2 Impact Assessment ...... 7 4 Recommended Management and Mitigation Measures ...... 11
LIST OF FIGURES
Figure 2-2: Field Ratings Methodology ...... 2 Figure 2-1: CS Determination Methodology...... 3 Figure 3-1: Graphical Representation of Impact Assessment Concept ...... 5 Figure 3-2: Example of how Potential Impacts are considered ...... 5
LIST OF TABLES
Table 3-1: Description of Duration, Extent, Intensity and Probability Ratings Used in the Impact Assessment ...... 8 Table 3-2: Impact Significance Scores, Descriptions and Ratings ...... 10 Table 3-3 Relationship between Consequence, Probability and Significance ...... 10 Table 4-1: Minimum Recommended Management or Mitigation Requirements Considering CS ...... 11
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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999
1 Introduction Cultural heritage resources are intrinsic to the history and beliefs of communities. They characterise community identity and cultures, are finite, non-renewable and irreplaceable. Considering the innate value of cultural heritage resources, Heritage Resources Management (HRM) acknowledges that these have lasting worth as evidence of the origins of life, humanity and society. It is incumbent of the assessor to determine the cultural significance1 (CS) of cultural heritage resources to allow for the implementation of appropriate management. This is achieved through assessing cultural heritage resources’ value relative to certain prescribed criteria encapsulated in policies and legal frameworks, such as the South African National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA). Commensurate to the NHRA, with specific reference to Section 38, this methodology aims to ensure that clients protect cultural heritage during implementation of project activities by either avoiding, removing or reducing the intensity of adverse impacts to tangible2 and intangible3 cultural heritage resources within the defined area of influence. The methodology to define CS and assess the potential effects of a project is discussed separately in the sections below.
2 Evaluation of Cultural Significance and Field Ratings
2.1 Cultural Significance Determination Digby Wells developed a CS Determination Methodology to assign identified cultural heritage resources with a numerical CS rating in an objective as possible way and that can be independently reproduced provided that the same information sources are used, should this be required. This methodology determines the intrinsic, comparative and contextual significance of identified cultural heritage resources by considering their: 1. Importance rated on a six-point scale against four criteria; and 2. Physical integrity rated on a five-point scale.
1 Cultural significance is defined as the intrinsic “aesthetic, architectural, historical, scientific, social, spiritual, linguistic or technological value or significance” of a cultural heritage resource. These attributes are combined and reduced to four themes used in the Digby Wells significance matrix: aesthetic, historical, scientific and social. 2 (i) Moveable or immovable objects, property, sites, structures, or groups of structures, having archaeological (prehistoric), paleontological, historical, cultural, artistic, and religious values; (ii) unique natural features or tangible objects that embody cultural values, such as sacred groves, rocks, lakes, and waterfalls. 3 Cultural knowledge, innovations, and practices of communities embodying traditional lifestyles.
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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999
The assigned ratings consider information obtained through a review of available credible sources and representativity or uniqueness (i.e. known examples of similar resources to exist), as well as the current preservation status-quo as observed. Figure 2-2 depicts the CS formula and importance criteria, and it describes ratings on the importance physical integrity scales
2.2 Field Rating Determination Grading of heritage resources remains the responsibility of heritage resources authorities. However, the South African Heritage Resources Agency (SAHRA) Minimum Standards requires heritage reports include Field Ratings for identified resources to comply with section 38 of the NHRA. Section 7 of the NHRA provides for a system of grading of heritage resources that form part of the national estate and distinguishes between three categories. The field rating process is designed to provide a numerical rating of the recommended grading of identified heritage resources. The evaluation is done as objectively as possible by integrating the field rating into the significance matrix. Field ratings guide decision-making in terms of appropriate minimum required mitigation measures and consequent management responsibilities in accordance with Section 8 of the NHRA. Figure 2-1 presents the formula and the parameters used to determine the Field Ratings.
Figure 2-1: Field Ratings Methodology
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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999
Figure 2-2: CS Determination Methodology
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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999
3 Impact Assessment Methodology
The rationale behind CS determination recognises that the value of a cultural heritage resource is a direct indication of its sensitivity to change (impacts) as well as the maximum acceptable levels of change to the resource. Therefore, the assessor must determine CS prior to the completion of any impact assessment. These requirements in terms of international best practice standards are integrated into the impact assessment methodology to guide both assessments of impacts and recommendations for mitigation and management of resources. The following are terms and definitions applicable to the Environmental Impact Assessment (EIA) concept (ISO 14001): ■ Project Activity: Activities associated with the Project that result in an environmental interaction during various phases, i.e. construction, operation and decommissioning, e.g., new processing plant, new stockpiles, development of open pit, dewatering, water treatment plant; ■ Environmental Interaction: An element or characteristic of an activity, product, or service that interacts or can interact with the environment. Environmental interactions can cause environmental impacts (but may not necessarily do so). They can have either beneficial impacts or adverse impacts and can have a direct and decisive impact on the environment or contribute only partially or indirectly to a larger environmental change; ■ Environmental Aspect: Various natural and human environments that an activity may interact with. These environments extend from within the activity itself to the global system, and include air, water, land, flora, fauna (including people) and natural resources of all kinds; and ■ Environmental Impact: A change to the environment that is caused either partly or entirely by one or more environmental interactions. An environmental interaction can have either a direct and decisive impact on the environment or contribute only partially or indirectly to a larger environmental change. In addition, it can have either a beneficial environmental impact or an adverse environmental impact.
The assessment process identified potential issues and impacts through examination of: ■ Project phases and activities, ■ Interactions between activities and the environmental aspect; and ■ The interdependencies between environmental aspects.
Figure 3-1 presents a graphical summary of this concept and Figure 3-2 provides an example of the process.
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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999
Figure 3-1: Graphical Representation of Impact Assessment Concept
Project Activity & Interaction Environmental Aspect Potential Environmental Impact
Issue Potential Impact Aspect Interdependencies Project Phase Activity
This relates to the This refers to one This identifies This identifies The issues Potential impacts consideration of or more of the and considers the and considers the considers the are a culmination the relevant activities that will various aspects interdepndencies activity in relation of the various phase of the be undertaken that will be between the to the identified categories project. during the affected by the various aspects aspects and evaluated as part Example: corresponding project activity. and how they interdepndencies. of the impact Construction phase of the Example: may be impacted Note: Activities assessment. project. Heritage, upon by the and Aspects can Example: Topsoil Example: Topsoil Biophysical, and relevant activity. have several clearing will clearing Social Example: issues resulting in remove Removal of various impacts. medicinal plants topsoil will Example: that will erode impact on flora Physical indigenous which may have alteration of the knowledge heritage and land systems and social cultural implications significance.
Figure 3-2: Example of how Potential Impacts are considered
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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999
3.1 Categorising Impacts to Cultural Heritage Impacts may manifest differently among geographical areas and diverse communities. For instance, impacts to cultural heritage resources can simultaneously affect the tangible cultural heritage resource and have social repercussions. The severity of the impact is compounded when the intensity of physical impacts and social repercussions differ significantly, e.g. removal of a grave surface dressings results in a minor physical impact but has a significant social impact. In addition, impacts to cultural heritage resources can influence the determined CS without a physical impact taking place. Given this reasoning, impacts as considered here are generally placed into three broad categories (adapted from Winter & Bauman 2005: 36): ■ Direct or primary impacts affect the fabric or physical integrity of the cultural heritage resource, for example destruction of an archaeological site or historical building. Direct or primary impacts may be the most immediate and noticeable. Such impacts are usually ranked as the most intense, but can often be erroneously assessed as high-ranking. For example, the destruction of a low-density scatter of archaeological material culture may be assessed as a negatively high impact if CS is not considered; ■ Indirect, induced or secondary impacts can occur later in time or at a different place from the causal activity, or because of a complex pathway. For example, restricted access to a cultural heritage resource resulting in the gradual erosion of its CS that may be dependent on ritual patterns of access. Although the physical fabric of the cultural heritage resource is not affected through any primary impact, its CS is affected, which can ultimately result in the loss of the resource itself; and ■ Cumulative impacts result from in-combination effects on cultural heritage resources acting within a host of processes that are insignificant when seen in isolation, but which collectively have a significant effect. Cumulative effects can be: ▪ Additive: the simple sum of all the effects, e.g. the total number of development activities that will occur within the study area; ▪ Synergistic: effects interact to produce a total effect greater than the sum of the individual effects, e.g. the effect of each different activity on the archaeological landscape in the study area; ▪ Time crowding: frequent, repetitive impacts on a cultural heritage resource at the same time, e.g. the effect of regular blasting activities on a nearby rock art site or protected historical building; ▪ Neutralizing: where the effects may counteract each other to reduce the overall effect, e.g. the effect of changes in land use could reduce the overall impact on sites within the archaeological landscape of the study area; and/or
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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999
▪ Space crowding: high spatial density of impacts on a cultural heritage resource, e.g. density of new buildings resulting in suburbanisation of a historical rural landscape.
The fact that cultural heritage resources do not exist in isolation from the wider natural, social, cultural and heritage landscape demonstrates the relevance of the above distinctions: CS is therefore also linked to rarity / uniqueness, physical integrity and importance to diverse communities.
3.2 Impact Assessment The impact assessment process is designed to provide a numerical rating of the identified potential impacts. This methodology follows the established impact assessment formula:
Impact = consequence of an event x probability of the event occurring
where:
Consequence = type of impact x (Duration + Extent + Intensity)
and
Probability = Likelihood of an impact occurring
In the formula for calculating consequence:
Type of impact = +1 (positive) or -1 (negative)
Table 3-1 presents a description of the duration, extent, intensity and probability ratings. The intensity rating definitions consider the determined CS of the identified cultural heritage resources. These criteria are used to determine the impact ratings as defined in Table 3-2 below. Table 3-3 represents the relationship between consequence, probability and significance. The impact assessment process considers pre- and post-mitigation scenarios with the intention of managing and/or mitigating impacts in line with the EIA Mitigation Hierarchy, i.e. avoiding all impacts on cultural heritage resources. Where Project-related mitigation does not avoid or sufficiently minimise negative impacts on cultural heritage resources, mitigation of these resources may be required.
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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999
Table 3-1: Description of Duration, Extent, Intensity and Probability Ratings Used in the Impact Assessment
CONSEQUENCE PROBABILITY RATING - A measure of the chance DURATION RATING - A measure of the lifespan of EXTENT RATING A measure of how wide the INTENSITY RATING- A measure of the degree of that consequences of that selected level of Value the impact impact would occur harm, injury or loss. severity could occur during the exposure window.
Probability Description Exposure Description Intensity Description Probability Description
Impacts on heritage resources Happens frequently. Impact will permanently alter will have international The impact will occur or change the heritage repercussions, issues or Major change to Heritage regardless of the 7 Permanent resource and/or value International effects, i.e. in context of Extremely high Resource with High-Very High Certain/Definite implementation of any (Complete loss of international cultural Value preventative or corrective information) significance, legislation, actions. associations, etc. Impacts on heritage resources Impact will reduce over time will have national Moderate change to Heritage Happens often. after project life (Mainly repercussions, issues or 6 Beyond Project Life National Very high Resource with High-Very High High probability It is most likely that the impact renewable resources and effects, i.e. in context of Value will occur. indirect impacts) national cultural significance, legislation, associations, etc.
Impacts on heritage resources will have provincial Minor change to Heritage The impact will cease after repercussions, issues or Could easily happen. 5 Project Life Region High Resource with High-Very High Likely project life. effects, i.e. in context of The impact may occur. Value provincial cultural significance, legislation, associations, etc. Impacts on heritage resources will have regional Major change to Heritage Could happen. Impact will remain for >50% - 4 Long Term Municipal area repercussions, issues or Moderately high Resource with Medium- Probable Has occurred here or Project Life effects, i.e. in context of the Medium High Value elsewhere regional study area.
Has not happened yet, but Impacts on heritage resources Moderate change to Heritage could happen once in a lifetime Impact will remain for >10% - will have local repercussions, Unlikely / Low 3 Medium Term Local Moderate Resource with Medium - of the project. 50% of Project Life issues or effects, i.e. in context probability Medium High Value There is a possibility that the of the local study area. impact will occur.
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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999
CONSEQUENCE PROBABILITY RATING - A measure of the chance DURATION RATING - A measure of the lifespan of EXTENT RATING A measure of how wide the INTENSITY RATING- A measure of the degree of that consequences of that selected level of Value the impact impact would occur harm, injury or loss. severity could occur during the exposure window.
Probability Description Exposure Description Intensity Description Probability Description
Conceivable, but only in extreme circumstances.
Have not happened during the Impacts on heritage resources lifetime of the project, but has will have site specific Minor change to Heritage happened elsewhere. The Impact will remain for <10% 2 Short Term Limited repercussions, issues or Low Resource with Medium - Rare / Improbable possibility of the impact of Project Life effects, i.e. in context of the Medium High Value materialising is very low as a site-specific study area. result of design, historic experience or implementation of adequate mitigation measures
Impact may be Impacts on heritage resources No change to Heritage sporadic/limited duration and will be limited to the identified Resource with values medium can occur at any time. E.g. Highly Unlikely Expected never to happen. 1 Transient Very Limited resource and its immediate Very low or higher, or Any change to Only during specific times of /None Impact will not occur. surroundings, i.e. in context of Heritage Resource with Low operation, and not affecting the specific heritage site. Value heritage value.
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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999
Table 3-2: Impact Significance Scores, Descriptions and Ratings
Score Description Rating
109 to 147 A very beneficial impact which may be sufficient by itself to justify implementation of the project. The impact may result in permanent positive change. Major (positive)
A beneficial impact which may help to justify the implementation of the project. These impacts would be considered by society as constituting a major and usually a long-term positive change to the 73 to 108 Moderate (positive) heritage resources.
An important positive impact. The impact is insufficient by itself to justify the implementation of the project. These impacts will usually result in positive medium to long-term effect on the heritage 36 to 72 Minor (positive) resources.
3 to 35 A small positive impact. The impact will result in medium to short term effects on the heritage resources. Negligible (positive)
An acceptable negative impact for which mitigation is desirable but not essential. The impact by itself is insufficient even in combination with other low impacts to prevent the development being -3 to -35 Negligible (negative) approved. These impacts will result in negative medium to short term effects on the heritage resources.
An important negative impact which requires mitigation. The impact is insufficient by itself to prevent the implementation of the project but which in conjunction with other impacts may prevent its -36 to -72 Minor (negative) implementation. These impacts will usually result in negative medium to long-term effect on the heritage resources.
A serious negative impact which may prevent the implementation of the project. These impacts would be considered by society as constituting a major and usually a long-term change to the heritage -73 to -108 Moderate (negative) resources and result in severe effects.
-109 to - A very serious negative impact which may be sufficient by itself to prevent implementation of the project. The impact may result in permanent change. Very often these impacts are immitigable and Major (negative) 147 usually result in very severe effects.
Table 3-3 Relationship between Consequence, Probability and Significance
Relationship between consequence, probability and significance ratings
Significance
7 -147 -140 -133 -126 -119 -112 -105 -98 -91 -84 -77 -70 -63 -56 -49 -42 -35 -28 -21 21 28 35 42 49 56 63 70 77 84 91 98 105 112 119 126 133 140 147
6 -126 -120 -114 -108 -102 -96 -90 -84 -78 -72 -66 -60 -54 -48 -42 -36 -30 -24 -18 18 24 30 36 42 48 54 60 66 72 78 84 90 96 102 108 114 120 126
5 -105 -100 -95 -90 -85 -80 -75 -70 -65 -60 -55 -50 -45 -40 -35 -30 -25 -20 -15 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 105
4 -84 -80 -76 -72 -68 -64 -60 -56 -52 -48 -44 -40 -36 -32 -28 -24 -20 -16 -12 12 16 20 24 28 32 36 40 44 48 52 56 60 64 68 72 76 80 84
3 -63 -60 -57 -54 -51 -48 -45 -42 -39 -36 -33 -30 -27 -24 -21 -18 -15 -12 -9 9 12 15 18 21 24 27 30 33 36 39 42 45 48 51 54 57 60 63 Probability 2 -42 -40 -38 -36 -34 -32 -30 -28 -26 -24 -22 -20 -18 -16 -14 -12 -10 -8 -6 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42
1 -21 -20 -19 -18 -17 -16 -15 -14 -13 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
-21 -20 -19 -18 -17 -16 -15 -14 -13 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Consequence
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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999
4 Recommended Management and Mitigation Measures
The CS of an identified heritage resource informs the level of the identified potential impact to that resource which in turn informs the recommended management and mitigation requirements. Table 4-1 presents an overview of the minimum recommended mitigation requirements considering the CS of the heritage resource. Table 4-1: Minimum Recommended Management or Mitigation Requirements Considering CS
Determined CS Minimum Management / Mitigation Requirements4
Negligible Sufficiently recorded through assessment, no mitigation required
Resource must be recorded before destruction, may include detailed Low mapping or surface sampling
Mitigation of the resource to include detailed recording and limited test Medium excavations Project design must aim to minimise impacts; Medium-High Mitigation of resources to include extensive sampling through test excavations and analysis Project design must aim to avoid impacts; High Cultural heritage resource to be partially conserved, must be managed by way of Conservation Management Plan Project design must be amended to avoid all impacts; Very High Cultural heritage resources to be conserved in entirety and conserved and managed by way of Conservation Management Plan
The desired outcome of an impact assessment is the avoidance of all negative impacts and enhancement of positive ones. While this is not always possible, the recommended management or mitigation measures must be reasonable and feasible taking into consideration the determined CS and nature of the Project. Two categories of impact management options are considered: avoidance and mitigation. Avoidance requires changes or amendments to Project design, planning and siting of infrastructure to avoid physical impacts on heritage resources. It is the preferred option, especially where cultural heritage resources with high – very-high CS will be impacted.
4 Based on minimum requirements encapsulated in guidelines developed by SAHRA
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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999
Mitigation of cultural heritage resources may be necessary where avoidance is not possible, thus resulting in partial or complete changes (including destruction) to a resource. Such resources need to be protected until they are fully recorded, documented and researched before any negative impact occurs. Options for mitigating a negative impact can include minimization, offsets, and compensation. Examples of mitigation measures specific to cultural heritage include: ■ Intensive detailed recording of sites through various non-intrusive techniques to create a documentary record of the site – “preservation by record”; and ■ Intrusive recording and sampling such as shovel test pits (STPs) and excavations, relocation (usually burial grounds and graves, but certain types of sites may be relocated), restoration and alteration. Any form of intrusive mitigation is normally a regulated permitted activity for which permits5 need to be issued by the Heritage Resource Authorities (HRAs). Such mitigation may result in a reassessment of the value of a cultural heritage resource that could require conservation measures to be implemented. Alternatively, an application for a destruction permit may be made if the resource has been sufficiently sampled.
Where resources have negligible CS, the specialist may recommend that no further mitigation is required, and the site may be destroyed where authorised. Community consultation is an integral activity to all above-mentioned avoidance and mitigation measures.
5 Permit application processes must comply with the relevant Section of the NHRA and applicable Chapter(s) of the NHRA Regulations, 2000 (Government Notice Regulation [GN R] 548) and must be issued by SAHRA or the Provincial Heritage Resources Authority (PHRA) as is applicable.
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