Reference No: LP 30/5/1/2/3/2/1/10102EM SAHRIS Case ID: 7331

Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province

Heritage Impact Assessment

Project Number:

VMC3049

Prepared for: Pamish Investments No. 39 (Pty) Ltd

July 2015

______Digby Wells and Associates (South Africa) (Pty) Ltd (Subsidiary of Digby Wells & Associates (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 11 789 9498, [email protected], www.digbywells.com ______Directors: DJ Otto, GB Beringer, LF Koeslag, AJ Reynolds (Chairman) (British)*, J Leaver*, GE Trusler (C.E.O) *Non-Executive ______

This document has been prepared by Digby Wells Environmental.

Report Type: Heritage Impact Assessment

Proposed Open Pit Magnetite Mine and Concentrator Plant, Project Name: Mokopane, Limpopo Province

Project Code: VMC3049

Name Responsibility Signature Date

Justin du Piesanie Reconnaissance and Heritage Management May 2015 Consultant: Archaeologist Report Compilation ASAPA Member 270

Tammy Hodgskiss Reconnaissance and Stone Age Specialist Specialist Stone Age May 2015

ASAPA Member: 258 Report

Johan Nel HRM Unit Manager Technical Review May 2015

ASAPA Member 095

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 Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

EXECUTIVE SUMMARY

Pamish Investments No. 39 (Pty) Ltd (Pamish) are proposing to develop a new opencast Magnetite mine approximately 35 km northwest of Mokopane town in the Limpopo Province (i.e. the Magnetite Project). Digby Wells Environmental (Digby Wells) was appointed to undertake the environmental and social studies required for the Right Application and Environmental Authorisation, according to national legislative requirements and international best practices standards and principles. Digby Wells compiled a Notification of Intent to Develop (NID) and Heritage Scoping Report (HSR) as part of the specialist heritage study. The NID and HSR were submitted to the South African Heritage Resources Agency (SAHRA) and Limpopo Heritage Resources Authority (LIHRA) via the South African Heritage Resources Information System (SAHRIS) (Case ID: 7331) on 12 March 2015 for Statutory Comment as prescribed under section 38(8) of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA). This document constitutes the draft Heritage Impact Assessment (HIA) to inform the greater Environmental and Social Impact Assessment (ESIA) Report. The primary aim of this HIA report, including the NID and HSR, was to furnish the responsible Heritage Resources Authorities with details regarding the location, nature and extent of the proposed development, and the possible impacts associated. The key deliverables as part of this assessment included an HIA and Statutory Comment Feedback (SCF) Report. A pre-disturbance survey was conducted as an adaptive, non-intrusive (i.e. no sampling was undertaken) pedestrian pre-disturbance survey to cover the extent of the development footprint area within the allocated time. Identified heritage resources were recorded as waypoints using a handheld GPS and documented through written and photographic records. A total of 47 heritage resources were identified during the reconnaissance of the development footprint. These are summarised in the following table:

Identified Heritage Resources Number

Middle Stone Age (c. 300 kya to 30 kya) (MSA) 37

Occurrence 37

7331/SA-006 1

7331/SA-007 1

7331/SA-009 1

7331/SA-010 1

7331/SA-012 1

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Identified Heritage Resources Number

7331/SA-013 1

7331/SA-015 1

7331/SA-016 1

7331/SA-004 1

7331/SA-005 1

7331/SA-019 1

7331/SA-020 1

7331/SA-021 1

7331/SA-022 1

7331/SA-024 1

7331/SA-025 1

7331/SA-027 1

7331/SA-028 1

7331/SA-029 1

7331/SA-030 1

7331/SA-031 1

7331/SA-032 1

7331/SA-033 1

7331/SA-034 1

7331/SA-036 1

7331/SA-037 1

7331/SA-038 1

7331/SA-039 1

7331/SA-040 1

7331/SA-041 1

7331/SA-042 1

7331/SA-043 1

7331/SA-044 1

7331/SA-045 1

7331/SA-046 1

7331/SA-047 1

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Identified Heritage Resources Number

7331/SA-049 1

Late Farming Communities (c. 1000 CE to 1820 CE) 9

Late Farming Community site 3

7331/FC-002 1

7331/FC-003 1

7331/FC-018 1

Occurrence 6

7331/FC-011 1

7331/FC-014 1

7331/FC-023 1

7331/FC-026 1

7331/FC-035 1

7331/FC-048 1

Democratic Republic of South Africa (1994 to present) 1

Burial / grave 1

7331/BGG-001 1

Grand Total 47

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

The findings from the study indicated that the following impacts can be expected:

Pre-mitigation Post-mitigation

Code Impact

Extent Extent

Duration Intensity Duration Intensity

Probability Probability

Significance Significance

Consequence Consequence

Alteration to

Stone Age Landscape Very low - Moderately Moderate Municipal Very low - Slightly Negligible Direct-SAL Permanent Local Certain Immediate Probable in negative detrimental - negative Area positive beneficial - positive development footprint

Indirect

impacts on

farming Indirect- Very high Extremely Moderate Beyond High - Moderately Moderate community Permanent National Likely Limited Certain Tang_Farming - negative detrimental - negative project life positive beneficial - positive sites - tangible resources

Indirect

impacts on Beyond Very low - Moderately Minor - Very low - Negligible Indirect-IKS Indigenous Local Likely Short term Very limited Negligible Likely project life negative detrimental negative positive - positive Knowledge Systems

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In relation to the impacts identified the following recommendations apply: ■ Identified heritage resources with negligible significance have been sufficiently recorded and no further mitigation is required on these individual accumulations; ■ Notwithstanding the negligible cultural significance of individual Stone Age accumulations, the overall distribution of these sites suggest a potential for subsurface deposit that could contribute to the understanding of the Stone Age Landscape of the study area, specifically MSA habitation. It is recommended that augering or Shovel Test Pits (STPs) of the development footprint be undertaken prior to pre-construction activities with the necessary permits regulated under Section 35 of the NHRA; ■ Stone Age accumulations suggest that there is a potential for subsurface deposit that could contribute to the understanding of the Stone Age Landscape of the study area, specifically MSA habitation. It is recommended that augering or STPs of the development footprint be undertaken prior to pre-construction activities with the necessary permits regulated under Section 35 of the NHRA to contribute to the knowledge of the MSA habitation of the area. This must be undertaken by a qualified archaeologist; ■ To address the indirect impact on farming community stonewalled sites and the additive cumulative impact on the cultural landscape, record identified sites on Malokong Hill in detail through archaeological mitigation and detailed mapping prior to pre-construction activities with the necessary permits regulated under Section 35 of the NHRA. This must be undertaken by a qualified archaeologist; ■ Chance Find Protocols (CFPs) must be developed and included as a condition of authorisation that outline reporting structures and management processes for the accidental discovery or exposure of unknown heritage resources during construction and operational phases of the Magnetite Project. Where previously unidentified burial grounds and graves are identified in the development footprint, a Burial Grounds and Consultation Process (BGGC) as regulated by Section 36 of the NHRA and Chapter XI of the Regulations to the Act must be implemented to: . Identify as far as possible bona fide Next-of-Kin (NoK); and . Consult and reach agreement with NoK as to the appropriate management of the burial ground or grave either through a Conservation Management Plan (CMP) or if required, Grave Relocation Plan (GRP).

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

TABLE OF CONTENTS

1 Introduction ...... 1

1.1 Project Background ...... 1 1.2 Terms of Reference ...... 1 1.3 Scope of Work ...... 2 1.4 Expertise of the Specialist ...... 2 1.5 Constraints and Limitations ...... 3 2 Aims and Objectives ...... 4

3 Methodology ...... 4

3.1 Quantitative Data Collection...... 4 3.2 Mitigation Measures and Recommendations ...... 5 4 Consultation ...... 7

4.1 Records of Formal Stakeholder Engagement ...... 7 4.2 Heritage ...... 9 4.2.1 Graves ...... 9 4.2.2 Intangible / Living Heritage ...... 11 4.2.3 Sites ...... 11 4.3 Traditional Leadership / Community Representation ...... 11 4.4 Records of Informal Consultation ...... 13 5 Updated Baseline Environment ...... 13

5.1 Geological Landscape ...... 13 5.2 Fluvial Processes ...... 14 5.3 and Sediments ...... 14 5.4 Farming Communities ...... 15 5.5 Socio-Political History / Historical Context ...... 16 5.6 Results of Reconnaissance ...... 16 5.6.1 BGG-001 / Burial ground ...... 17 5.6.2 FC-002 / Late Farming Community ...... 17 5.6.3 FC-003 / Late Farming Community ...... 18

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

5.6.4 SA-004 / Stone Age ...... 19 5.6.5 SA-005 / Stone Age ...... 19 5.6.6 SA-006 / Stone Age ...... 20 5.6.7 SA-007 / Stone Age ...... 20 5.6.8 SA-009 / Stone Age ...... 21 5.6.9 SA-010 / Stone Age ...... 21 5.6.10 FC-011 / Late Farming Community ...... 22 5.6.11 SA-012 / Stone Age ...... 23 5.6.12 SA-013 / Stone Age ...... 23 5.6.13 FC-014 / Late Farming Community ...... 24 5.6.14 SA-015 / Stone Age ...... 24 5.6.15 SA-016 / Stone Age ...... 25 5.6.16 FC-018 / Late Farming Community ...... 25 5.6.17 SA-019 / Stone Age ...... 26 5.6.18 SA-020 / Stone Age ...... 26 5.6.19 SA-021 / Stone Age ...... 27 5.6.20 SA-022 / Stone Age ...... 27 5.6.21 FC-023 / Late Farming Community ...... 28 5.6.22 SA-024 / Stone Age ...... 28 5.6.23 SA-025 / Stone Age ...... 29 5.6.24 FC-026 / Late Farming Community ...... 29 5.6.25 SA-027 / Stone Age ...... 30 5.6.26 SA-028 / Stone Age ...... 30 5.6.27 SA-029 / Stone Age ...... 31 5.6.28 SA-030 / Stone Age ...... 31 5.6.29 SA-031 / Stone Age ...... 32 5.6.30 SA-032 / Stone Age ...... 32 5.6.31 SA-033 / Stone Age ...... 33 5.6.32 SA-034 / Stone Age ...... 33 5.6.33 FC-035 / Late Farming Community ...... 34 5.6.34 SA-036 / Stone Age ...... 34

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

5.6.35 SA-037 / Stone Age ...... 35 5.6.36 SA-038 / Stone Age ...... 36 5.6.37 SA-039 / Stone Age ...... 36 5.6.38 SA-040 / Stone Age ...... 37 5.6.39 SA-041 / Stone Age ...... 37 5.6.40 SA-042 / Stone Age ...... 38 5.6.41 SA-043 / Stone Age ...... 38 5.6.42 SA-044 / Stone Age ...... 39 5.6.43 SA-045 / Stone Age ...... 39 5.6.44 SA-046 – Stone Age ...... 40 5.6.45 SA-047 / Stone Age ...... 40 5.6.46 FC-048 / Late Farming Communities ...... 41 5.6.47 SA-049 / Stone Age ...... 41 6 Sensitivity Analysis and No-Go Area ...... 42

7 Heritage Impact Assessment ...... 45

7.1 Methodology ...... 45 7.1.1 Evaluation of Significance ...... 45 7.1.2 Field Ratings ...... 46 7.1.3 Impact Assessment ...... 48 7.2 Risk versus Impact ...... 54 7.3 Cultural Significance ...... 54 7.4 Impact Assessment ...... 61 7.4.1 Direct Impacts on Stone Age Resources ...... 62 7.4.2 Indirect Impact on Farming Community Sites ...... 65 7.4.3 Indirect Impact on Indigenous Knowledge Systems...... 69 8 Cumulative Impacts on the Cultural Landscape ...... 72

9 Unplanned Events and Low Risks ...... 74

9.1 Low Risk to Karst Landscape ...... 75 9.2 Low Risks to Burial Grounds and Graves ...... 76 10 Conclusion...... 77

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

LIST OF FIGURES

Figure 5-1: View of BGG-001 and Site Extent (in yellow) ...... 17 Figure 5-2: View of FC-002 and Site Extent (in yellow) ...... 18 Figure 5-3: View of FC-003 and Site Extent (in yellow) ...... 18 Figure 5-4: View of Stone Tool at SA-004 and Site Location ...... 19 Figure 5-5: View of Stone Tools at SA-005 and Site Location ...... 20 Figure 5-6: View of Stone Tools at SA-006 and Site Location ...... 20 Figure 5-7: View of Stone Tools at SA-007 and Site Location ...... 21 Figure 5-8: View of Stone Tools at SA-009 and Site Location ...... 21 Figure 5-9: View of Stone Tool at SA-010 and Site Location ...... 22 Figure 5-10: View of Scatter at FC-011 and Site Location ...... 22 Figure 5-11: View of stone tools at SA-012 and site location ...... 23 Figure 5-12: View of Flake at SA-013 and Site Location ...... 23 Figure 5-13: View of Potsherd and Site Location ...... 24 Figure 5-14: View of Flake at SA-015 and Site Location ...... 24 Figure 5-15: View of Stone Tools and Site Location ...... 25 Figure 5-16: View of Site at FC-018 and Site Extent (in yellow) ...... 25 Figure 5-17: Site Location SA-019 ...... 26 Figure 5-18: View of Stone Tools at SA-020 and Site Location ...... 27 Figure 5-19: View of Flake at SA-021 and Site Location ...... 27 Figure 5-20: View of Stone Tools at SA-022 and Site Location ...... 28 Figure 5-21: View of Ceramic Scatter at FC-023 and Site Location ...... 28 Figure 5-22: View of Stone Tools at SA-024 and Site Location ...... 29 Figure 5-23: View of Artefact Scatter at SA-025 and Site Location ...... 29 Figure 5-24: View of Artefact Scatter at FC-026 and Site Location...... 30 Figure 5-25: View of Flakes at SA-027 and Site Location ...... 30 Figure 5-26: View of Flake at SA-028 and Site Location ...... 31 Figure 5-27: View of Stone Tools at SA-029 and Site Location ...... 31 Figure 5-28: Site Location of SA-030 ...... 32

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Figure 5-29: Site Location of SA-031 ...... 32 Figure 5-30: View of Stone Tools at SA-032 and Site Location ...... 33 Figure 5-31: Site Location of SA-033 ...... 33 Figure 5-32: View of Stone Tool at SA-034 and Site Location ...... 34 Figure 5-33: View of Potsherds at FC-035 and Site Location ...... 34 Figure 5-34: View of Stone Tools at SA-036 and Site Location ...... 35 Figure 5-35: View of Stone Tools at SA-037 and Colluvial Path ...... 35 Figure 5-36: View of Flake at SA-038 and Site Location ...... 36 Figure 5-37: Site Location of SA-039 ...... 36 Figure 5-38: View of Stone Tools at SA-040 and Site Location ...... 37 Figure 5-39: View of Scatter at SA-041 and Site Location ...... 37 Figure 5-40: View of Scatter at SA-042 and Site Location ...... 38 Figure 5-41: View of Flake at SA-043 and Site Location ...... 38 Figure 5-42: View of Flakes at SA-044 and Site Location ...... 39 Figure 5-43: View of Stone Tools at SA-045 and Site Location ...... 39 Figure 5-44: View of Artefact Scatter at SA-046 and Site Location ...... 40 Figure 5-45: View of Stone Tool at SA-047 and Site Location ...... 40 Figure 5-46: View of Potsherd and Site at FC-048 ...... 41 Figure 5-47: View of Stone Tools at SA-049 and Site Location ...... 42 Figure 7-1: Stonewalled Settlement on the South-Western Portion of Malokong Hill ...... 66 Figure 7-2: The Approximate Extent of the Stonewalled Settlement indicated in yellow ...... 67 Figure 9-1: Ground Vibration Over Distance for the Two Charge Masses used in Modelling76

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

LIST OF TABLES

Table 4-1: Meetings Held as Part of Public Participation Process ...... 7 Table 4-2: Extract of the Comments and Response Table from the CRR ...... 9 Table 5-1: Dominant Types and Slopes occurring within the Study Area ...... 14 Table 7-1: Ratings and Descriptions used in Determining CS and Field Ratings ...... 47 Table 7-2: Description of Duration, Extent, Intensity and Probability Ratings used in Impact Assessment ...... 51 Table 7-3: Impact Significance Ratings, Categories and Relationship between Consequence, Probability and Significance ...... 53 Table 7-4: Summary of Identified Heritage Resources Grading and Significance ...... 55 Table 7-5: Cultural Significance of Identified Heritage Resources ...... 56 Table 7-6: Project Activities ...... 61 Table 7-7: Identified Stone Age Accumulations with Negligible Significance ...... 63 Table 7-8: Significance Ratings for the Stone Age Landscape of the Study Area ...... 64 Table 7-9: Summary of Impact Assessment related to the Damage and/or Destruction of the Stone Age Landscape ...... 64 Table 7-10: Summary of Impact Assessment related to Indirect Impacts on Late Farming Community Sites ...... 68 Table 7-11: Medicinal Plants Species Recorded within the Magnetite Project ...... 69 Table 7-12: Summary of Impact Assessment for the Indirect Impact on IKS ...... 71 Table 8-1: Summary of Potential Cumulative Impacts ...... 72 Table 9-1: Unplanned Events, Low Risks and their Management Measures ...... 74 Table 9-2: Cultural Significance Rating for the Karst Topography within the Study Area ...... 75

LIST OF PLANS

Plan 1: Heritage Sensitivity Analysis for the Magnetite Project ...... 43 Plan 2: Identified Heritage Resources ...... 44

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

LIST OF APPENDICES

Appendix A: Declaration of Independence Appendix B: Specialists CV Appendix C: Stone Age Report

LIST OF TERMS

Term Definition

Material remains resulting from human activity that are in a state of

disuse and older than 100 years, including artefacts, human and hominid

remains and artificial features and structures. Rock art created through human agency older than 100 years, including any area within 10 m of such representation. Wrecks older than 60 years - either vessels or Archaeological aircraft - or any part thereof that was wrecked in South Africa on land, internal or territorial waters, and any cargo, debris or artefacts found or associated therewith. Features, structures and artefacts associated with military history that are older than 75 years and the sites on which they are found, e.g. battlefields.

A trained professional who uses scientific methods to excavate, record Archaeologist and study archaeological sites and deposits.

Artefact Any object manufactured or modified by human beings.

Burial Grounds and The regulated consultation process required in terms of Section 36 of the Graves Consultation NHRA and Regulation GNR 548 to the Act when burial grounds and (BGGC) graves are identified within a project area.

In an archaeological context any vessel or other object produced from

natural that has been fired. Indigenous associated with Ceramic (syn. pottery) Farming Communities are low-fired wares, typically found as potsherds. Imported and more historic ceramics generally include high-fired wares such as porcelain, stoneware, etc.

Subgroups of a primary ceramic tradition or sequence. Typically used in

ceramic analyses. Various facies are attributed to different temporal

periods based of radiometric dates obtained from archaeological Ceramic facies / facies contexts. Facies are often used to infer cultural identity of archaeological groups. However, in context of this study identified ceramic facies merely provide a relative temporal context for archaeological sites in the landscape.

The sequence of ceramic styles that develop out of each other and form Ceramic tradition a continuum. A tradition is the primary group to which subsequent ceramic facies belong. A ceramic tradition can be broadly associated

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Term Definition with various linguistic and cultural groups, but do not represent any given ethnic identity, especially during the LFC period. In relation to heritage resources includes the protection, maintenance, Conservation preservation and sustainable use of places or objects so as to safeguard their cultural significance.

The aesthetic, architectural, historical, scientific, social, spiritual,

linguistic or technological value or significance. A heritage may have

cultural significance or other special value because of its: Importance in the community, or pattern of South Africa’s history. Possession of uncommon, rare or endangered aspects of South Africa’s natural or cultural heritage

Potential to yield information that will contribute to an understanding of

South Africa’s natural or cultural heritage. Importance in demonstrating the principal characteristics of a particular Cultural significance class of South Africa’s natural or cultural places or objects. (CS) Importance in exhibiting particular aesthetic characteristics valued by a community or cultural group. Importance in demonstrating a high degree of creative or technical achievement at a particular period. Strong or special association with a particular community or cultural group for social, cultural or spiritual reasons. Strong or special association with the life or work of a person, group or organisation of importance in the history of South Africa. Significance relating to the history of slavery in South Africa.

Any physical intervention, excavation, or action, other than those caused

by natural forces, which may in the opinion of a heritage authority in any

way result in a change to the nature, appearance or physical nature of a place, or influence its stability and future well-being, including: Construction, alteration, demolition, removal or change of use of a place or a structure at a place. Development Carrying out any works on or over or under a place. Subdivision or consolidation of land comprising, a place, including the structures or airspace of a place. Constructing or putting up for display signs or hoardings. Any change to the natural or existing condition or topography of land. Any removal or destruction of trees, or removal of vegetation or topsoil. The first Farming Communities (also known as Early Age) that Early Farming appear in the southern archaeological record during the early first Community/ies millennium CE. The EFC period is generally dated from c. 200 CE to 1000 CE. The South African ESA dates from ~3 Mya to c. 250 Kya. This period is Early Stone Age associated with later Australopithecus and early Homo species. The lithic industries that characterise the ESA include Oldowan and Early

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Term Definition Acheulian, typically as simple core tools, choppers handaxes and cleavers. The scientific excavation, recording and retrieval of archaeological Excavation deposit and objects through the use of accepted archaeological procedures and methods, and excavate has a corresponding meaning.

Term signifying the appearance in the southern African archaeological of

Bantu-speaking agricultural based societies from the early first

millennium CE. The term replaces the Iron Age as a more accurate description for groups who practiced agriculture and animal husbandry, Farming Community/ies extensive manufacture and use of ceramics, and metalworking. The Farming Community period is divided into an Early and Late phase. The use of Later Farming Communities especially removes the artificial boundary between archaeology and history.

SAHRA requires heritage resources to be provisionally rated in

accordance with Section 7 of the NHRA that provides a three tier grading

system of resources that form part of the national estate. The rating system distinguishes between four categories: Grade I: Heritage resources with qualities so exceptional that they are of special national significance. Field Rating Grade II: Heritage resources which, although forming part of the national estate, can be considered to have special qualities which make them significant within the context of a province or a region. Grade III: Other heritage resources worthy of conservation. General Protected: i.e. generally protected in terms of Sections 33 to 37 of the NHRA. Places with qualities so exceptional that they are of special national Formal protection significance as national heritage sites or that have special qualities as provincial heritage sites.

General protections are afforded to:

. Objects protected in terms of laws of foreign states; . Structures older than 60 years; General protection . Archaeological and palaeontological sites and material and meteorites; . Burial grounds and graves; and . Public monuments and memorials. A place of interment and includes the contents, headstone or other Grave marker of such a place, and any other structure on or associated with such place.

An assessment of the cultural significance of, and possible impacts on, Heritage Impact diverse heritage resources that may be affected by a proposed Assessment (HIA) development. A HIA may include several specialist elements such as archaeological, built environment and palaeontological studies. The HIA

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Term Definition must supply the heritage authority with sufficient information about the sites to assess, with confidence, whether or not it has any objection to a development, indicate the conditions upon which such development might proceed and assess which sites require permits for destruction, which sites require mitigation and what measures should be put in place to protect sites that should be conserved. The content of HIA reports are clearly outlined in Section 38(3) of the NHRA and SAHRA Minimum Standards.

Heritage resource Any place or object of cultural significance.

Process required when development is intended categorised as:

. Any linear development exceeding 300m in length; . Construction of a bridge or similar structure exceeding 50 m in length; . Any activity which will change the character of a site exceeding 0.5 Heritage resources hectares in extent or involving three or more existing erven or management subdivisions thereof or that have been consolidated within the past five years or costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources authority; . Re-zoning of a site exceeding one hectare in extent; and . Any other category of development provided for in regulations by SAHRA or a provincial heritage resources authority. Any place declared to be a national heritage site by SAHRA or a place Heritage site declared to be a provincial heritage site by a provincial heritage resources authority.

Farming Communities who either developed / evolved from EFC groups,

or who migrated into southern African from the late first millennium / early second millennium CE. The LFC period evidences distinct changes Late Farming in socio-political organisation, settlement patterns, trade and economic Community/ies activities, including extensive trade routes. The LFC period is generally dated from c. 1000 CE well into the modern historical period of the nineteenth century.

The South African LSA dates from ~30 Kya. This period is associated

with modern Homo sapiens sapiens and the complex hunter-gatherer

societies, ancestral to the Bushmen / San and Khoi. The LSA lithic Late Stone Age assemblage contains microlithic technology and composite tools such as arrows commonly produced from fine-grained cryptocrystalines, quarts and chert. The LSA is also associated with archaeological rock art including both paintings and engravings. The intangible aspects of inherited culture that could include cultural Living / intangible tradition, oral history, performance, ritual, popular memory, skills and heritage techniques, indigenous knowledge systems, the holistic approach to nature, society and social relationships.

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Term Definition

In relation to heritage resources, includes the conservation, presentation Management and improvement of a place protected in terms of the NHRA.

The South African MSA dates from ~300 Kya to c. 30 Kya. This period is

associated with the changing behavioural patterns and the emergence of

modern cognitive abilities in early Homo sapiens species. The lithic industries that characterise the MSA are typically more complex tools Middle Stone Age with diagnostic identifiers, including convergent flake scars, multi-faceted platforms, retouch and backing. Assemblages are characterised as refined lithic technologies such as prepared core techniques, retouched blades and points manufactured from good quality raw material.

The national estate as defined in Section 3 of the NHRA, i.e. heritage

resources of South Africa which are of cultural significance or other

special value for the present community and for future generations. The national estate may include: . Places, buildings, structures and equipment of cultural

significance.

. Places to which oral traditions are attached or which are associated with living heritage. . Historical settlements and townscapes. . Landscapes and natural features of cultural significance.

. Geological sites of scientific or cultural importance.

. Archaeological and palaeontological sites. . Graves and burial grounds, including ancestral graves, royal graves and graves of traditional leaders, graves of victims of conflict, graves of individuals designated by the Minister by notice National estate in the Gazette, historical graves and cemeteries, and other human remains which are not covered in terms of the National Health Act, 2003. . Sites of significance relating to the history of slavery in South Africa. . Movable objects, including objects recovered from the soil or waters of South Africa, including archaeological and palaeontological objects and material, meteorites and rare geological specimens; objects to which oral traditions are attached or which are associated with living heritage; ethnographic art and objects; military objects; objects of decorative or fine art; objects of scientific or technological interest. . Books, records, documents, photographic positives and negatives, graphic, film or video material or sound recordings, excluding those that are public records as defined in section 1(xiv) of the National Archives of South Africa Act, 1996 (Act No. 43 of 1996). Any fossilised remains or fossil trace of animals or plants which lived in Palaeontological the geological past, other than fossil fuels or fossiliferous rock intended for industrial use, and any site which contains such fossilised remains or

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Term Definition trance. A trained professional who uses scientific methods to excavate, collect, Palaeontologist record and study palaeontological sites and fossils.

A method of examining a site in which surveyors, spaced at regular Pedestrian survey intervals, systematically walk over the area being investigated.

Phase 1 Archaeological Phase 1 AIAs generally involve the identification and assessment of sites Impact Assessment during a field survey of a portion of land that is going to be affected by a (AIA) potentially destructive or landscape-altering activity.

Phase 2 AIAs are primarily based on salvage or mitigation excavations

preceding development that will destroy or impact on a site. This may

involve collecting of artefacts from the surface and / or excavation of representative samples of the artefactual material to allow Phase 2 Archaeological characterisation of the site and the collection of suitable materials for Impact Assessment dating the sites. Phase 2 AIAs aim to obtain a general idea of the age, (AIA) significance and meaning of the site that is to be lost and to store a sample that can be consulted at a later date for research purposes. Phase 2 excavations can only be done under a permit issued by SAHRA, or other appropriate heritage agency, to the appointed archaeologist.

On occasion, a site may require a Phase 3 programme involving the

modification of the site or the incorporation of the site into the

development itself as a site museum, a special conservation area or a display. Alternatively it is often possible to relocate or plan the development in such a way as to conserve the archaeological site or any other special heritage significance the place may have. For example, in a

wilderness area or open space when sites are of public interest the

development of interpretative material is recommended and adds value Phase 3 Management to the development. Permission for the development to proceed can be Plan / Conservation given only once the heritage resources authority is satisfied that Management Plan measures are in place to ensure that the archaeological sites will not be (CMP) damaged by the impact of the development or that they have been adequately recorded and sampled. Careful planning can minimise the impact of archaeological surveys on development projects by selecting options that cause the least amount of inconvenience and delay. The process as explained above allows the rescue and preservation of information relating to our past heritage for future generations. It balances the requirements of developers and the conservation and protection of our cultural heritage as required of SAHRA and the provincial heritage resources authorities (ASAPA).

A survey to record a site as it exists, with all the topographical and other Pre-disturbance survey information that can be collected, without excavation or other (syn. reconnaissance) disturbance of the site.

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Term Definition

A broad range of techniques involved in the location of archaeological

sites, e.g. surface survey and the recording of surface artefacts and

features, the sampling of natural and mineral resources, and sometimes testing of an area to assess the number and extent of archaeological Reconnaissance resources. However, in terms of South African practice, reconnaissance during a so-called Phase 1 AIA never includes sampling as this is a permitted activity, usually undertaken during so-called Phase 2 AIAs (ASAPA).

Any area of land, including land covered by water, and including any Site structures or objects thereon. Any building, works, device or other facility made by people and which is Structure fixed to land, and includes any fixtures, fittings and equipment associated therewith.

Physical heritage resources such as archaeological sites, historical

buildings, burial grounds and graves, fossils, etc. Tangible heritage may Tangible heritage be associated with intangible elements, e.g. the living cultural traditions, rituals and performances associated with burial grounds and graves and deceased persons.

LIST OF ACRONYMS

Acronyms Definition

AIA Archaeological Impact Assessment

ASAPA Association of Southern African Professional Archaeologists

BA Bachelor of Arts

BGG Burial Ground and Graves

BGGC Burial Ground and Graves Consultation c. circa, meaning approximately

CE Common Era

CFPs Chance Find Procedures cHIA Community Health Impact Assessment

CMP Conservation Management Plan

CRR Comments and Response Report

DEA Department of Environmental Affairs

Digby Wells Digby Wells Environmental

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Acronyms Definition

DMR Department of Mineral Resources

EA Environmental Authorisation

EAP Environmental Assessment Practitioner

EMP Environmental Management Programme

ESA Early Stone Age

ESIA Environmental and Social Impact Assessment

ESI Evolutionary Studies Institute

GIS Geographical Information System

GRP Grave Relocation Plan

HIA Heritage Impact Assessment

Hons Honours degree

HRM Heritage Resources Management

HSR Heritage Scoping Report

ICOMOS International Council on Monuments and Sites

IFC International Finance Corporation

IKS Indigenous Knowledge Systems km Kilometres

LIHRA Limpopo Heritage Resources Authority

LoM Life of Mine

LRE Letter of Request for Exemption

LSA Late Stone Age

Ma Million Years Ago

MA Master of Arts

MPRDA Minerals and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002)

MSA Middle Stone Age

MSc Master of Science

NEMA National Environmental Management Act, 1998 (Act No. 107 of 1998)

NHRA National Heritage Resources Act, 1999 (Act No. 25 of 1999)

NID Notification of Intent to Develop

NoK Next-of-Kin

Pamish Pamish Investments No. 39 (Pty) Ltd

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Acronyms Definition

PhD Doctoral degree

PPV Peak Particle Velocity

RoD Record of Decision

RoM Run of Mine

SAfA Society of Africanist Archaeologists

SAHRA South African Heritage Resources Agency

SAHRIS South African Heritage Resources Information System

SCF Statutory Comment Feedback

SEP Stakeholder Engagement Process

SIA Social Impact Assessment

SoW Scope of Work

STP Shovel Test Pit

ToR Terms of Reference

UP University of Pretoria

Wits University of the Witwatersrand

ZAR Zuid Afrikaanse Republiek

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1 Introduction

1 1.1 Project Background Pamish Investments No. 39 (Pty) Ltd (Pamish) are proposing to develop a new open pit Magnetite mine approximately 45 kilometres (km) northwest of Mokopane town in the Limpopo Province (i.e. the Magnetite Project). The applicant is bound by national legislation to submit a Mining Right Application (MRA) to the Department of Mineral Resources (DMR). Digby Wells Environmental (Digby Wells) was appointed to undertake the environmental and social baseline studies required for the MRA and EA, according to national legislative requirements and international best practices standards and principles. Digby Wells compiled a Notification of Intent to Develop (NID) and Heritage Scoping Report (HSR) as part of the specialist heritage study. The NID and HSR were submitted to the South African Heritage Resources Agency (SAHRA) and Limpopo Heritage Resources Authority (LIHRA) via the South African Heritage Resources Information System (SAHRIS) (Case ID: 7331) on 12 March 2015 for Statutory Comment as prescribed under section 38(8) of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA). This document constitutes the draft Heritage Impact Assessment (HIA) to inform the greater Environmental and Social Impact Assessment (ESIA) Report for the proposed Magnetite Project. This report must be read and understood in conjunction with the HSR.

1.2 Terms of Reference The Terms of Reference (ToR) for the HIA are based on the recommendations provided in the NID and HSR. These required that an HIA be completed and submitted to the relevant Heritage Resources Authorities (HRAs) prior to the development, and must include: ■ An Archaeological Impact Assessment (AIA) including reconnaissance to identify and record archaeological resources within the development footprint2; ■ An assessment of burial grounds and graves including reconnaissance to identify, record and document all burials that may exist in the development footprint; ■ Integration of additional specialist studies to determine any possible living heritage in the project area. Studies that may be considered for integration include Social Impact Assessment, Biophysical Assessment and Visual Assessment.

1 Detailed project descriptions, including, consideration of project alternatives, definitions, legal frameworks and baseline cultural landscape descriptions were reported on in the HSR and are not repeated in this report for the sake of brevity. The HSR is available from: http://www.sahra.org.za/cases/vmc3049pamishmagnatiteprojectesia. 2 The development footprint refers to the proposed location of all infrastructures and project related activities. This area falls within the greater site-specific project area defined by the farm portions on which the applicants prospecting right is held.

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1.3 Scope of Work The key deliverables as part of this assessment included an HIA and Statutory Comment Feedback (SCF) Report. The Scope of Work required to complete these deliverables, based on the ToR outlined in Section 1.2 above included: ■ Reconnaissance and pre-disturbance survey of the proposed development footprint; ■ Assessment of the cultural significance of any identified heritage resources; ■ Assessment of impacts on identified heritage resources; ■ Developing mitigation measures to avoid and / or reduce negative impacts and enhance positive ones; ■ Compilation of an HIA report; ■ Submission of the HIA report to SAHRA and LIHRA for Statutory Comment; ■ Compilation of an SCF Report.

1.4 Expertise of the Specialist Justin du Piesanie undertook the reconnaissance and compiled the HIA report. 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 through the University of Cape Town’s Faculty of Engineering and the Built Environment Continuing Professional Development Programme in 2013. He currently holds the position of Heritage Management Consultant: Archaeologist at Digby Wells. He has over 6 years combined experience in HRM in South Africa, including heritage assessments, archaeological mitigation and grave relocation. Justin has gained further generalist experience since his appointment at Digby Wells in Botswana, Burkina Faso, the Democratic Republic of Congo, Liberia and Mali on projects that have required compliance with International Finance Corporation (IFC) requirements such as Performance Standard 8: Cultural Heritage. Justin is a professional member of ASAPA (Member No. 270) and the International Council on Monuments and Sites (ICOMOS) South Africa (Member No. 14274). Tammy Hodgskiss completed the reconnaissance and compiled the specialist Stone Age report. She obtained her Doctor of Philosophy (PhD) degree in Archaeology from the University of the Witwatersrand in 2013. She specialised in Middle Stone Age Archaeology and ochre use-trace studies. She has over 8 years of experience in Stone Age research, excavation and laboratory techniques. She is currently a Postdoctoral Research Fellow at the Evolutionary Studies Institute (ESI) at the University of the Witwatersrand. Tammy is a professional member of the ASAPA (Member No. 258) and the Society of Africanist Archaeologists (SAfA).

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Johan Nel undertook the technical review of this HIA. He has more than 13 years of combined experience in the field of HRM including archaeological and heritage assessments, grave relocation, social consultation and mitigation of archaeological sites. He has gained experience both within urban settings and remote rural landscapes. Since 2010 he has been actively involved in environmental management that has allowed me to investigate and implement the integration of heritage resources management into EIAs. Many of the projects since have required compliance with IFC requirements such as Performance Standard 8: Cultural Heritage. This exposure has allowed Johan to develop and implement a HRM approach that is founded on international best practice, leading international conservation bodies such as the United Nations Educational, Scientific and Cultural Organisation (UNESCO) and ICOMOS and aligned to the South African legislation. Johan has worked in most South African Provinces, as well as Swaziland, the Democratic Republic of the Congo, Liberia and Sierra Leone. Johan is a professional member of ASAPA (Member No. 095) and ICOMOS South Africa (Member No. 13839). Refer to Appendix A for detailed specialist curriculum vitae.

1.5 Constraints and Limitations The following constraints and limitations were experienced during the completion of this study: ■ The NEMA Regulations that came into effect on 8 December 2014 significantly constrains timeframes within which studies can be completed; ■ While every effort was made to cover the development footprint as extensively as possible, this was constrained by the regulated timeframes; ■ Surface visibility and access was greatly reduced due to dense Dichrostachys cinerea (Sickle Bush) and grass cover. This in some instances limited exploration along prepopulated transects and ground visibility; ■ Archaeological sites commonly occur at sub-surface levels with no or limited trace evidence on the surface. To investigate the potential of subsurface occurrences, permits regulated under Section 35 of the NHRA is required. No permits were held by the specialists, and as such, it is possible that archaeological sites may be identified during the construction and operational phase of the Magnetite Project; ■ Open air Stone Age sites are easily disturbed. These disturbances affect the stratigraphic integrity of a site and remove artefacts from any temporal or spatial context. Establishing any temporal or functional relations between scatters of artefacts is difficult, especially so if the scatters cannot be related back to a high accumulation or site; and ■ The authors acknowledge that the recent historical landscape is complex: issues such as succession disputes are representative of an inherent complex and

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conflicted heritage that is the current subject of much research and public debate. The death of the previous Bakenberg chief in 2014 has resulted in an apparent succession dispute. There is also evident conflict between village leadership and the current Traditional Council, evidenced in comments raised during meetings held as part of the SEP. However, a comprehensive study of these issues is outside the scope of this study.

2 Aims and Objectives The primary aim of this HIA report, including the NID and HSR, was to furnish the responsible HRAs with details regarding the location, nature and extent of the proposed development, and the possible impacts associated. The specific objectives of the HIA report were to enable the responsible HRAs to: ■ Timeously decide, in consultation with the proponent, i.e. Pamish, whether or not the development may proceed; ■ Stipulate any limitations or conditions to be applied to the development; ■ Determine what general protections apply in terms of the NHRA, and what formal protections may be consequently be applied; ■ Determine if any compensatory action is required in respect of any heritage resources damaged or destroyed as a result of the development; and ■ Determine the need to appoint specialists as a condition of approval of the proposed development.

3 Methodology Information collated in the HSR assisted in the development of a cultural heritage baseline profile for the study area, as well as determining cultural significance and assessing heritage impacts. Where necessary, qualitative data presented in the HSR was updated. The HIA places emphasis on quantitative (i.e. field based) data collected, specifically tangible heritage. The methodology adopted is discussed below.

3.1 Quantitative Data Collection Justin du Piesanie and Tammy Hodgskiss (refer to Appendix A for the specialists CV) collected field based data for the HIA between 23 and 27 March 2015. The survey focussed on the proposed development footprint3 of the Magnetite Project.

3 Quantitative data collection focussed on the development footprint designed after the sensitivity analysis as presented in Plan 1. The development footprint has subsequently been amended and is presented in Plan 2. The impact assessment considers the final development footprint design.

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The objectives of the survey were to: ■ Verify heritage resources identified during the scoping assessment; ■ Visually record the current state of the cultural landscape; ■ Ground truth certain heritage identified in the literature; and ■ Record all tangible heritage resources within the proposed development footprint.

The survey was conducted as an adaptive, non-intrusive (i.e. no sampling was undertaken) pedestrian pre-disturbance survey to cover the extent of the development footprint area within the allocated time. The total footprint area was over 450 hectares and surveyed over five days, recorded as a GPS track log (see Plan 2). Identified heritage resources were recorded as waypoints using a handheld GPS and documented through written and photographic records. The Pit 2 and Plant development footprints were subject to random surveys, i.e. not following transects, to allow as much coverage as possible. Specific attention was, however, paid to surface indicators that generally indicate the presence of archaeological and historical sites, e.g. distinct changes in vegetation. The Waste Rock Dump, Top Soil Dump and Pit 1 development footprints were surveyed following structured, systematic survey techniques. East to west transects4 were plotted over the over the development footprint at 150 m intervals. The Tailings Dam development footprint area was subject to systematic survey along north to south transects at 150 m intervals.

3.2 Mitigation Measures and Recommendations The desired outcome of an impact Designation Recommended mitigation assessment is the removal of Negligible Sufficiently recorded, no mitigation required negative impacts on heritage Resource must be recorded before destruction, including detailed site mapping, Low resources through the surface sampling may be required implementation of feasible mitigation Mitigation of resource to include detailed recording and mapping, and limited Medium measures. The mitigation and sampling, e.g. STPs. management measures Project design should aim to reduce or remove changes; recommended in this section comply Medium High Mitigation of resource to include extensive sampling and recording, e.g. test excavation, analyses, etc. with the General Principles set out Project design must aim to avoid change to resource; High under Section 5 of the NHRA. The Partly conserved, Conservation Management Plan (CMP) recommendations further considered Project design must change to avoid all change to resource; Very High the cultural significance of heritage Conserved in entirety, CMP resources and the recommended Box 1: Recommended minimum level of required mitigation minimum level of mitigation as

4 Transects served as a guide to assist in the systematic survey of the development footprint. It must be noted however that the natural topography and vegetation cover restricted movement through the landscape. While every attempt to adhere to transects was undertaken, this may not have been possible at all times.

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published in the South African Heritage Resources Agency (SAHRA) Minimum Standards5 (See Box 1). Recommended mitigation is therefore divided into two categories: project related and mitigation of heritage resources defined below. ■ Project-related mitigation requires changes or amendments to project design, planning and siting of infrastructure to avoid or reduce physical impacts on heritage resources. Project-related mitigation measures are always the preferred option, especially where heritage resources with higher cultural significance will be impacted on. Project-related mitigation may include: . In situ preservation (i.e. no-development) of heritage resources for which Conservation Management Plans (CMPs) are required; and . Conservation of heritage resources through, for example, incorporating the resources into project design and planning, for which CMPs are also required.

■ Mitigation of heritage resources may be necessary where project-related mitigation will not sufficiently conserve or preserve heritage resources, thus resulting in partial or complete changes (including destruction) to a resource. Such resources need to be mitigated to ensure that they are fully recorded, documented and researched before any negative change occurs. This may require mitigation such as: . Intensive detailed recording of sites through various non-intrusive techniques to create a documentary record of the site – “preservation by record”; . 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 a regulated permitted activity for which permits need to be issued by the relevant heritage authorities. Such mitigation may result in a reassessment of the value of a 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; and . Where resources have negligible significance the specialist may recommend that no further mitigation is required and the site may be destroyed, for which a destruction permit must be applied for.

Appropriate mitigation measures were identified for each impact, and the procedure discussed above was to assess the possible consequence, probability and significance of each impact post-mitigation.

5 It must be noted that these minimum standards serve as a guide, and the recommendations provided in this HIA are project specific.

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The post-mitigation rating provided an indication of the significance of residual impacts, while the difference between an impact’s pre- and post-mitigation ratings represents the degree to which the recommended mitigation measures are expected to be effective in reducing or ameliorating that impact.

4 Consultation Formal and informal consultation was undertaken by the heritage specialists. Formal consultation was undertaken by Johan Nel (Manager: HRM) during the Stakeholder Engagement Process (SEP) conducted from 20 to 30 April 2014. The aim was to capture and address any issues raised by community members and other stakeholders during key stakeholder, land owner, village and public meetings. t Informal consultation was undertaken by the archaeologists during the reconnaissance of the Magnetite Project study area. Records of consultation are summarised below.

4.1 Records of Formal Stakeholder Engagement Official comments and responses were recorded as part of the SEP conducted as part of the Scoping phase of the mining right process regulated by the 2014 EIA Regulations. The following engagement methods were undertaken to record stakeholder comments: ■ Village meetings; ■ Commercial Farmers Meeting; ■ Key Stakeholders Meeting; ■ Public Meeting; ■ Focus Group Meeting with landowners; ■ Telephonic consultations with stakeholders; and ■ Written submissions from stakeholders on the Scoping Report.

A total of 14 meetings were held from 23 – 31 March 2015. The details of these meetings are presented in Table 4-1 below. Table 4-1: Meetings Held as Part of Public Participation Process

No. Meeting Day and Time Date

1 Bakenberg Traditional Council Monday, 08:00 23 March 2015

2 Pudiakagopa Monday, 12:00 23 March 2015

3 Taolome Monday, 15:00 23 March 2015

Malokongskop, Rooiwal Mabusela, 4 Tuesday, 08:00 24 March 2015 and Kwenaite

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No. Meeting Day and Time Date

5 Ditlotswana Tuesday, 15:00 24 March 2015

6 Kaditshwene Wednesday, 08:00 25 March 2015

7 Sepharane Wednesday, 13:00 25 March 2015

8 Basogadi Wednesday, 15:00 25 March 2015

9 Commercial Farmers Thursday, 13:00 26 March 2015

10 Key stakeholders Friday, 13:00 27 March 2015

11 Public Meeting Saturday, 09:00 28 March 2015

12 Mautjane Monday, 12:00 30 March 2015

13 Claremont Tuesday, 12:00 31 March 2015

14 Good Hope Tuesday, 15:00 31 March 2015

All comments and responses are recorded in the Comments and Response Report (CRR). This section summarised specific heritage issues that were recorded during the SEP.

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Table 4-2: Extract of the Comments and Response Table from the CRR

Organisation / Comment raised Contributor Date Method Response Community

4.2 Heritage Heritage sites will be identified through the HIA process. The How will heritage be protected? Phillip Lebeto Sepharane 25 March 2015 Village Meeting community must assist in identifying heritage sites. All heritage resources are protected under NHRA.

Thank you for your indication that development of a proposed Open pit Magnetite is to take place in this area. You indicated that Heritage Impact Assessment Studies will be conducted. We therefore are looking Limpopo Heritage Thank you for the comment, the HIA will be submitted to your forward to receiving the Heritage Impact Assessment V Ramala 20 March 2015 Written correspondence Resources Authority office in due course. study that will be undertaken for our comments. We trust that you will submit the above report in due course. Should there be any queries, please do not hesitate to contact the undersigned.

4.2.1 Graves

Gravesites that are located in the proposed mine footprint area

will be included in the HIA as far as possible, but identification

will require assistance from communities. Graves are protected in terms of NHRA and may only be exhumed and relocated after Will graves be affected? Seleka Pila Claremont 31 March 2015 Village Meeting comprehensive consultation process is completed with the relatives of the deceased. In the event that human remains are accidentally exposed, a formal regulated process must be followed.

Digby Wells understands that graves are very sensitive heritage

resources. The HIA will recommend appropriate measures to the Applicant to comply with the NRHA requirements that Please be respectful to graves. Ephraim Madibela Kwenaite / Moutjane 30 March 2015 Village Meeting graves must be respected as well as the customs and beliefs of any person or community concerned with graves or burial grounds.

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Organisation / Comment raised Contributor Date Method Response Community

The project area is at least 8 km away from Kwenaite; it is

therefore unlikely that any graves will be affected. However, all

graves are protected under SA legislation. The HIA will document gravesites. If there are graves in the project area, these will be avoided as far as possible. If a grave cannot be What will happen to graves? Jonas Malapile Kwenaite / Moutjane 30 March 2015 Village Meeting protected grave relocation will be required. This process will need to be done in compliance with the NHRA and other legislation, in consultation with affected families. The community must assist in identifying gravesites as specialist can only record what they can see.

There are graves between Ditlotswane and Noted - the location of these graves will be verified to see if they Samuel Seabo Kwenaite / Moutjane 30 March 2015 Village Meeting Malokongskop. fall within the project area.

All graves are protected under South African (SA) legislation;

the first thing will be to complete a HIA. Specialists will survey

mine area to determine if there are any graves in the project area. If there are graves, these will be avoided as far as When the mine is going to be blasting, there will be Phillip Lebeto Sepharane 28 March 2015 Public Meeting possible. If there is a grave that cannot be moved Grave impacts on graves. Resettlement Process (GRP) will be required which will include a process to identify relatives and consult with them, however the community must assist in identifying heritage sites as the specialist can only record what they can see.

Abel Kotzé & Stephanus Trekdrift Boerdery BK Registration & Comment Gravesites will be included in the HIA. It first will need to be A 100-year old family graveyard on Pt 4 of Bellevue. 26 March 2015 Kotzé (Bellevue Pt. 5) Form established if this gravesite falls within the area of disturbance.

The participants at the meeting indicated that there are no Are there any graves known in the project area? Johan Nel Basogadi 25 March 2015 Village Meeting graves as far as they know in the project area.

Project area is at least 10 km away from Kaditshwene, it is How will graves be affected? Samuel Ngobeni Kaditshwene 25 March 2015 Village Meeting unlikely that any graves will be affected.

Gravesites will be included in the HIA as far as possible, but

identification will require assistance from communities. Graves

are protected in terms of NHRA and may only be exhumed and What will happen to graves that are behind Flora Mabusela Malokongskop 24 March 2015 Village Meeting relocated after a comprehensive consultation process Malokongskop? completed with the relatives of the deceased. The first option will be to leave graves where they are. Only where the safety of graves and/or relatives is affected should graves be relocated.

Gravesites will be included in the HIA as far as possible, but

identification will require assistance from communities. Graves

are protected in terms of NHRA and may only be exhumed and How will graves be relocated? Mabusela Esrom Malete Pudiakgopa Village 23 March 2015 Village Meeting relocated after a comprehensive consultation process is completed with relatives of the deceased. In the event that human remains are accidentally exposed, a formal regulated process must be followed.

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Organisation / Comment raised Contributor Date Method Response Community

4.2.2 Intangible / Living Heritage

Medicinal plants are part of the cultural heritage of people and

will be addressed in the Fauna and Flora, HIA, Social Impact How will open pit mining and resulting dust affect Magaetsi Manaka Ditlotswane 24 March 2015 Village Meeting Assessment (SIA), Community Health Impact Assessment traditional medicinal plants? (cHIA), and ecological studies. But people must inform specialists of plant use and areas where they might occur.

4.2.3 Sites

There is a historical cemetery located on Portion 4 of The mine will be situated approximately 10Km away from the Bellevue, dating from 1912. Also several built Abel Kotze Bellevue farmer / owner 26 March 2015 Village Meeting farm it is unlikely that there will be any impacts on these structures older than 60 years still exist on the farm heritage resources but this will be confirmed in the HIA. such as an Italian Prisoner of War (POW) built a canal.

Chance Find Procedures (CFPs) will be included in the HIA to mitigate against accidental exposure of heritage sites. All What will happen to unidentified sites? Lesiba Makgakga Bakenberg TC 23 March 2015 Bakenberg TC Meeting heritage sites are protected in accordance with NHRA, irrespective of whether they have been recorded or not. The proposed project area contains important historical heritage sites including the battles of the Bakenberg The HIA will aim to identify heritage sites, but assistance from Mr Mphela Sepharane 23 March 2015 Bakenberg TC Meeting succession dispute and there is a mass grave of local community will be required. warriors who died in the battles. Heritage resources will be identified through the HIA. The NHRA

How will heritage be protected? How can heritage protects certain categories of heritage resources. Heritage management be integrated into Social and Labour Plan Phillip Lebelo Sepharane 23 March 2015 Bakenberg TC Meeting management can be recommended to be included in e.g. SLP, (SLPs), Local Economic Development (LEDs), etc. but won’t be specifically addressed or implemented as this will be through the HIA.

4.3 Traditional Leadership / Community Representation

As the community they were requested to elect A date after Easter will be discussed with Mosate and village representatives. When will Pamish meet with them and Richard Sethoga Ditlotswane 28 March 2015 Public Meeting leadership where representatives will be elected. how will reps be elected?

The communication breakdown is between Mosate and the community. It is well known that meetings between Izingwe and Pamish and Mosate have been held. Why Mildred Maluleke Goedehoop 28 March 2015 Public Meeting Noted, thank you for your comment. doesn't Mosate communicate with community when people visit Mosate?

Mosate was invited. The Applicant and DW cannot answer on Community fears they have unanswered questions as behalf of the Mosate. Comments and concerns are recorded they were supposed to be welcomed by the TC. TC is September Majadibudu Morulaneng 28 March 2015 Public Meeting and will be submitted to DMR who will need to make a decision not at meeting to give answers. on the issues raised.

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Organisation / Comment raised Contributor Date Method Response Community Mosate was invited. The Applicant and DW cannot answer on Wanted Mosate to answer issues regarding their Morulaneng / behalf of the Mosate. Comments and concerns are recorded M H Lekutso 28 March 2015 Public Meeting knowledge of process. Haakdoringdraai. and will be submitted to DMR who will need to make a decision on the issues raised.

He is from Sebita, part of TC. Asks that people go to Sebetha Sebita 28 March 2015 Public Meeting Noted. Bakenberg and to the kgoros to hear about project.

Taolome always experiences issues when The Applicant wants to consult all villages, including Mosate / commitments are made by developers. Benefits go to TC Villages must therefore elect representatives to sit on Alfred Rachekhu Taolome 27 March 2015 Village Meeting Mosate / Bakenberg TC. Community ends up with committees. The Applicant cannot become involved in local nothing. politics.

Community representatives may form foundation from which a

Trust can be established. Trust and share schemes are

dependent on the awarding of the MR. The Trust will involve Will the Trust and benefits be administrated through Constance Mabonyane Sepharane 25 March 2015 Village Meeting surrounding villages through their representatives. Induna or the TC? Funds will be paid into a trust account. Trustees will be appointed from the mine and communities to administer the trust. Noted. A process is underway to consult with individual villages Pamish must only speak to elected representatives, not as well as the TC. All villages and TC to come together as a Dinah Letsoko Sepharane 25 March 2015 Village Meeting individual people. committee. The Applicant prefers not to deal with separate individuals as this creates issues.

The community must note that all benefits are dependent on the

awarding of the MR. Benefits may be in form of shares, but Sepharane is subject to the TC. Will benefits be shareholding structure and administration is still uncertain, but administered by the village or TC. Will benefits be Johannes Mošidi Sepharane 25 March 2015 Village Meeting may include elected representatives from communities and the awarded monthly, quarterly or annually. TC. The Applicant is still considering various options, but is committed that the community will benefit.

Pamish must contact Malokongskop community directly Thank you for your comment. This will be forwarded to the Solly Pitseng Malokongskop 24 March 2015 Village Meeting and not communicate through TC. Applicant for consideration. Pamish must consult directly with local villages. In the Noted. A process is underway to consult with individual villages past other mines consulted through the TC who did not Daniel Mashaba Malokongskop 24 March 2015 Village Meeting as well as the TC. All villages and TC to come together as a communicate the projects to villages. committee for purposes of consultation.

Community was unaware of the Project, The TC did not Maria Langa Ditlotswane 24 March 2015 Village Meeting Thank you for your comment. communicate the project to the villages.

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4.4 Records of Informal Consultation An informal conversation was conducted with Mr Frank Mabushala on 24 March 2015. Mr Mabushala is a cattle herder from Pudiakagopa who has grown up in the area and is familiar with the site specific study area. Mr Mabushala was asked as to whether he was aware of any archaeological sites, specifically stonewalled settlements, or graves within the development footprint area of the Magnetite Project. Mr Mabushala was only aware of the stonewalled settlement on Malokong Hill, on the eastern boundary of the project area and outside of the development footprint. He was not aware of any graves within the development footprint area, and only knew of the formal cemeteries in the surrounding towns.

6 5 Updated Baseline Environment

5.1 Geological Landscape Formations of the Transvaal Supergroup underlay the Bushveld Complex, with surface exposures of the Pretoria Group occurring within the south-western region of the project area. The Pretoria Group is underlain by the Chuniespoort Group with surface exposures occurring approximately 6 km to the east of the project area. Of significance within the Chuniespoort Group are the dolomites of the Malmani Subgroup. This geological formation is dated to between c.2600 and 2000 Ma. The Malmani Group dolomites feature stromatolites that contain the oldest evidence of cyanobacteria and hold to the potential for the development of karst topography and breccia formation. Karst topography refers to landscapes formed from the dissolution of soluble rocks, such as dolomite and limestone, resulting in voids (caves and sinkholes) which can develop as an extensive interconnected system. These karst formations are significant for their aquifer properties as well as potential archaeological discoveries relating to hominid palaeontology. The Malmani dolomites located within the study area are geologically associated with the more extensive Makapan Valley karst landscape, but are outside of this protected area. The Makapan valley is located approximately 40 km south-east of the project area. In addition, the dolomites identified in prospecting study area are at least 2.5 km from the development footprint.

6 The detailed literature review is available in the HSR. Detailed information contained within the literature review is not repeated herein for the sake of brevity. The updated baseline environment presented is a summary of the most salient points contained within the literature review and specialist Stone Age Report attached as Appendix B.

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5.2 Fluvial Processes Fluvial and colluvial action affect the landscape and distribution of the archaeological record. Descriptions of these processes are discussed here to provide context for the assessment of identified heritage resources presented in Section 7. The Mogalakwena River is located approximately 6 km from the project area. The Borobela, one of its tributaries is located to the north-west of the Magnetite Project. These are the main watercourses that run through the local study area, with no other tributaries or streams within the development footprint area. The Mogalakwena River, once a bedrock river is now a fluvial river due to the flow transport capacity being outpaced by the sediment supply. This is explained further below. Global glacial and interglacial cycles directly affect sediment deposition and aggradation. Fine-grained (clay and silt) sediment accumulation along the tributaries is likely to have increased during periods where vegetation is reduced due to arid and cooler or warmer conditions. Subsequent heavy rainfall generates large amounts of runoff water containing medium-coarse grained sediments resulting in additional tributary fan formation and progradation along the distal tributaries. This ultimately resulted in the gradual westward migration of the river toward the Waterberg. This process is likely to have resulted in the deposition of raw material.

5.3 Soils and Sediments The soils and sediments within the development footprint are likely to have been modified by fluvial and colluvial processes associated with the gradual westward movement of the Mogalakwena River. Additionally, the soils and sediments may have influenced the vertical distribution of identified Stone Age accumulations and ceramic scatters. A summary of the various types are soils are presented here to provide context for the assessment of identified heritage resources discussed under Section 7. The soils found within the study area are presented in Table 5-1. They predominantly comprised Colluvium (Ah), Vertic (Ea) and Iron Rich Red Soil (Ae). Table 5-1: Dominant Soil Types and Slopes occurring within the Study Area

Dominant Land Potential occurrence Dominant soil types Dominant slope % Type %

Red soils such as Oakleaf, 40 2 Clovelly, Dundee Ia Black clay soils such as 20 2 Valsrivier, Bonheim

A mix of shallow rocky soils Ah 3 – 15 1.5 – 2.9 and heavy structured clays

Ae Mixed red soils 70 3.5 - 4

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Dominant Land Potential occurrence Dominant soil types Dominant slope % Type %

Ea Black clay soils 90 2.8 - 3

Colluvium (Ah) is found near the base of Malokong Hill. It is a grey-white clayey soil containing a large coarse element such as rock fragments, pebbles, pieces of and calcrete. Vertic soils (Ea) are easily identified by an intensively cracked surface. They are brown-grey clayey soils which have stones and pebbles lying on top of it. Vertic soils are shrink-swell formations formed by continual and intensive shrinking and swelling of sediments in wet and dry periods. This shrink and swell periods cause any friable soil components to become fragmented and fine particles are rearranged, forming cracks when dry. The coarse elements in the soil, such as rock fragments, cannot be fragmented and are pushed towards the soil surface, often getting deposited on the surface. This causes the sorting of stones and particles through the sediment, with stone fragments and pebbles being deposited on or near the surface, removed from their primary context. The bright red soil is accompanied by a slight change in vegetation with fewer bushes and more grassland. These soils are mostly found near areas that have been historically used for agriculture, and possibly indicate soil that was previously ploughed or cultivated. Large quantities of (unutilised) and magnetite nodules are found in this soil.

5.4 Farming Communities Ceramic classification is universally used by archaeologists to establish relative cultural- historical temporal sequences within southern African Farming Communities. The predominant ceramics reported in the regional study area include several facies dating from the 14th century to the 1800s. In addition to ceramics, stonewalling is perhaps the most visible surface indicator of Farming Communities sites. Within the regional context stonewalled sites are primarily associated with the Moor Park cluster that is accepted as being of Nguni origin. During the 17th and 18th centuries, Nguni-speaking people moved north into Waterberg region. These Nguni-groups became known as so-called Northern Ndebele, of whom the Langa Ndebele are the present descendants. In addition the Langa Ndebele, there are also LIA sites that can be associated with earlier Sotho-Tswana occupation. However, given the nature of these early chiefdoms, the Nguni immigrants married local women, joined or were joined by other Sotho or Nguni groups. The Ndebele and Pedi residing in the region today are the descendants or modern manifestations of these intricate relationships. Ceramic sherds and stone walled settlements were identified during the scoping survey of the project area, as well as in several archaeology and heritage studies previously

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completed in the region. The ceramics provide evidence of Farming Communities settlement from at least the 17th century CE continuing to the 19th century CE. The combination of the various ceramic facies and types of stonewalled sites provide evidence of long-term occupation by Kekana and Langa Northern Ndebele as well as other groups.

5.5 Socio-Political History / Historical Context There is sufficient evidence that prove continuity from Farming Communities settlement into the historic period, and the division must be understood as largely artificial. The site-specific study area is located within the historic Bakenberg Location, also known as the Hendrik Masibi Location, one of the three original chiefdoms described above. The area is at present under the Bakenberg Tribal Authority’s jurisdiction. The scoping survey, historical aerial images and previously completed assessment studies have provided evidence for several archaeological and historic stonewalled sites within the study area. This includes Hendrik Masibi’s historic early 20th century capital that was indicated during the scoping survey. Previously completed heritage studies have investigated sites associated with the history of the Langa in the study area. These sites include Malokong Hill situated on the eastern border of the project area where a large stone walled settlement was identified. The settlement type conforms to a typical Nguni settlement pattern associated with the Moor Park cluster. According to this study, the Mabusela clan occupied the area throughout living memory, first settling at the highest point of the hill for security expanding the settlement over five stages. This site was verified during the scoping survey and was noted in historical aerial imagery dating from 1953 through to 2012.

5.6 Results of Reconnaissance Reconnaissance of the proposed infrastructure development footprint was undertaken over 4 days from 23 March 2015 up to and including 26 March 2015. This footprint has subsequently been revised, and all identified heritage resources are discussed in relation to the final development footprint. During the field survey, 47 heritage resources were identified; these are presented on the consolidated distribution plan below (See Plan 2on page 44). The results of the reconnaissance are presented below, discussing the individual resources identified. The cultural significance of these identified heritage resources are discussed under Section 7.

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5.6.1 BGG-001 / Burial ground

Field Rating: Co-ordinates Cultural Significance: Very High Grade IV A -23.911369 28.814409

Cemetery for the Ditlotswana community. The cemetery is situated off the D4380 provincial road some 600 m north-west of the Ditlotswana residential area. The cemetery is located outside of the proposed infrastructure footprint, approximately 700 m south of the planned Tailings Storage Facility (TSF) and 1.5 km east of the Topsoil Dump for Pit 2. The cemetery is fenced off and access is controlled by a gate. It appears that the cemetery is well kept, although it was slightly overgrown at the time of the reconnaissance. The graves within the cemetery amount to approximately 100. A large portion of these graves have granite tombstones and surface dressing. There are also a fair amount that has stone dressing and no tombstones.

Figure 5-1: View of BGG-001 and Site Extent (in yellow)

5.6.2 FC-002 / Late Farming Community

Field Rating: Co-ordinates Cultural Significance: High Grade III B -23.88267 28.81175

The location of an extensive stone walled settlement on the southern portion of Malokong Hill. The physically surveyed area covers a radius of more than 550 m over the hill, where stone walling, middens and material culture remains were recorded. The extent of the site could potentially extend beyond this area. Stone walling occurs from the base of Malokong Hill, and is terraced up against the slope. A large concentration of stone walling occurs on top of the hill, accessible through a natural depression in the hill. The location offers a clear view of the surrounding area to both the east and west of the settlement. The site is situated within the Royal Granite Supplies-Red (Pty) Ltd granite mine, and has been heavily impact upon. It currently lies approximately 270 m east, at the base of the hill,

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outside of the proposed Topsoil Dump for Pit 1.

Figure 5-2: View of FC-002 and Site Extent (in yellow)

5.6.3 FC-003 / Late Farming Community

Field Rating: Co-ordinates Cultural Significance: Low Grade IV A -23.873476 28.810861

Location of stone walling adjacent to a large cleared area at the base of Malokong Hill. The large cleared area could potential be the remnants of an old field associated with the site, or the other settlements located on the hill. The area is marked by a rock outcrop with stone walled enclosures built up against the sides, which could suggest that these served as enclosures for livestock. The stone walled enclosures measure approximately 20 m – 30 m in diameter. Some ceramic sherds were identified in the vicinity of this site, but none were decorated. The site is situated approximately 340 m east outside of the development footprint of the Topsoil Dump for Pit 1, within the granite mine area.

Figure 5-3: View of FC-003 and Site Extent (in yellow)

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5.6.4 SA-004 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.872497 28.81271

Few isolated MSA stone tools found around Malokong Hill on the road leading up the hill. One irregular cortical core made of tuff. Found in a light brown, gravel-rich soil. The tools were found close to some stone walling, associated with FC-002. Lithics are found in a cleared area associated with the Royal Granite Supplies-Red (Pty) Ltd granite mine. This find spot is situated approximately 445 m outside of the development footprint area of the Topsoil Dump for Pit 1.

Figure 5-4: View of Stone Tool at SA-004 and Site Location

5.6.5 SA-005 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.873168 28.810916

Two MSA flake fragments found on and alongside dirt road at the base of Malokong Hill. One flake is made from quartz and the other from felsic tuff. Both have some irregular retouch along the sides. Found in a light brown, gravel-rich soil. This area is directly adjacent to SA-004 and associated with the FC-002 stone walling. The lithics are found in a disturbed area associated with the Royal Granite Supplies-Red (Pty) Ltd granite mine. This find spot is situated 340 m outside of the development footprint area of the Topsoil Dump for Pit 1.

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Figure 5-5: View of Stone Tools at SA-005 and Site Location

5.6.6 SA-006 / Stone Age

Field Rating Co-ordinates Cultural Significance: Negligible :Grade IV C -23.867225 28.807158

Low density concentration of Stone Age flakes. Raw material appears to comprise of felsic tuff. The identified lithics were located within the project area, 30 m from Pit 1 and a proposed Site Road, and 305 m north of the Topsoil Dump for Pit 1. These tools were identified within the dark clay vertic soils associated with the land type Ea, as describe in the specialist Soils Scoping Report.

Figure 5-6: View of Stone Tools at SA-006 and Site Location

5.6.7 SA-007 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.867256 28.805235

Low density concentration of Stone Age flakes. The raw material appears to comprise of felsic tuff. The identified flakes were located within the footprint of Pit 1 approximately 200 m west of SA-006. They also occurred in close proximity to a recently established borehole. These tools were identified within the dark clay vertic soils associated with the land type Ea, as describe in the specialist Soils Scoping Report.

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Figure 5-7: View of Stone Tools at SA-007 and Site Location

5.6.8 SA-009 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.873157 28.794913

A low density concentration of Stone Age flakes located within the footprint of the proposed Low Grade Stockpile, 360 m north of the Plant Area. Two of the identified flakes appear to be made with felsic tuff raw material. These tools were identified within the dark clay vertic soils associated with the land type Ea, as describe in the specialist Soils Scoping Report.

Figure 5-8: View of Stone Tools at SA-009 and Site Location

5.6.9 SA-010 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.873713 28.805220

A single MSA core located 40 m outside of Pit 1 footprint, and within the footprint of the Topsoil Dump for Pit 1. The tool was identified within the dark clay vertic soils associated with the land type Ea, as describe in the specialist Soils Scoping Report. No other tools were identified in the vicinity of this location.

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Figure 5-9: View of Stone Tool at SA-010 and Site Location

5.6.10 FC-011 / Late Farming Community

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.882601 28.790292

A ceramic scatter located within the footprint of the Waste Rock Dump. The ceramics are located in an area where there is a change in the soil from soft dark greyish turf to compacted red soils and magnetite. A low density scatter of ceramic sherds was identified in this area, but no other features were noted in the vicinity. The scatter is situated approximately 90 m east of the Contractors Camp and 120 m south of the Plant Area. The site is located within 100 m of an old agricultural field, and could potentially indicate that archaeological deposit exists within the sub-strata in the western portion of the project area. These artefacts were found in an area where the soils type changes from the dominant vertic soil to mixed red soils associated with the land type Ae, as described in the specialist Soils Scoping Report.

Figure 5-10: View of Ceramic Scatter at FC-011 and Site Location

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5.6.11 SA-012 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.883897 28.793005

A low density concentration of Stone Age flakes located 385 m east of the Contractors Camp and 285 m south of the Plant Area footprint. The tool was identified within the dark clay vertic soils associated with the land type Ea, as describe in the specialist Soils Scoping Report.

Figure 5-11: View of stone tools at SA-012 and site location

5.6.12 SA-013 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.898008 28.786075

A single flake identified in an area potentially used as an old field. The flake was located in the southern portion of the proposed Lower Grade Stockpile. The soils in this location differ from the mixed red soils found in the northern portion. The soil is more like the vertic soils described for other identified heritage resources.

Figure 5-12: View of Flake at SA-013 and Site Location

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5.6.13 FC-014 / Late Farming Community

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.898843 28.788459

Single isolated potsherd located in the southern portion of the proposed Lower Grade Stockpile. The area where the potsherd was identified could potentially be the remains of an old agricultural field. The soils in this area are dark clay vertic soils associated with the land type Ea, as describe in the specialist Soils Scoping Report.

Figure 5-13: View of Potsherd and Site Location

5.6.14 SA-015 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.912548 28.795965

A single Stone Age flake located within the footprint of Pit 2. The tool was identified within the dark clay vertic soils associated with the land type Ea, as describe in the specialist Soils Scoping Report.

Figure 5-14: View of Flake at SA-015 and Site Location

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5.6.15 SA-016 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.911225 28.796940

A low density scatter of Stone Age flakes. The artefacts were located within the footprint of Pit 2, approximately 180 m north of SA-015. One of the flakes was identified as a unifacial point made from felsic tuff. These tools were identified within the dark clay vertic soils associated with the land type Ea, as describe in the specialist Soils Scoping Report

Figure 5-15: View of Stone Tools and Site Location

5.6.16 FC-018 / Late Farming Community

Field Rating: Co-ordinates Cultural Significance: Low Grade IV A -23.865365 28.818201

Stone walled settlement on the northern portion of Malokong Hill, directly adjacent to area mined for granite. Stone walling is terraced up the slopes of the hill toward the top, and could potentially extend further than the area surveyed. The site is located over 950 m to the east of the north-eastern corner of the infrastructure footprint within the granite mine. The area is heavily disturbed through activities associated with the granite mine.

Figure 5-16: View of Site at FC-018 and Site Extent (in yellow)

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5.6.17 SA-019 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.871836 28.812772

Few isolated MSA flake fragments on and alongside the dirt road at the base of Malokong Hill. Flakes are informal with no retouch, but there are some with irregular flake removals. They are made of felsic tuff, some cortical from . They are near a colluvial path, in a light-grey calcrete-rich soil containing a lot of gravel. The find spot is situated outside of the project footprint area, 420 m from the Topsoil Dump for Pit 1.

Figure 5-17: Site Location SA-019

5.6.18 SA-020 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.870107 28.812971

Few isolated MSA flakes and flake fragments scattered on and alongside the dirt road at the base of Malokong Hill. Tools are made from felsic tuff. They were found near a colluvial path, soil is a light-grey clay with pebbles and a gravel component. The site is situated outside the development footprint, approximately 450 m from the Topsoil Dump for Pit 1.

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Figure 5-18: View of Stone Tools at SA-020 and Site Location

5.6.19 SA-021 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.869276 28.812199

Few individual MSA flakes just off the dirt road at the base of Malokong Hill. Tools are made from felsic tuff. One unretouched, convergent MSA flake. Soil is a light-grey clay with pebbles and contains a gravel component. The find spot is situated outside of the development footprint, approximately 400 m from the Topsoil Dump for Pit 1.

Figure 5-19: View of Flake at SA-021 and Site Location

5.6.20 SA-022 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV B 23.868844 28.810585

Low density scatter of MSA flakes and flake fragments. Some with irregular retouch on the sides. Tools are made from felsic tuff and quartz. Situated near a colluvial channel in brown- grey vertic soil associated with the land type Ea. This scatter is situated outside of the development footprint area, approximately 275 m north of the Topsoil Dump for Pit 1. This scatter is 40 m from another low density scatter of

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artefacts, FC-023, which is situated in the same colluvial system.

Figure 5-20: View of Stone Tools at SA-022 and Site Location

5.6.21 FC-023 / Late Farming Community

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.86881 28.810236

Low density scatter of Stone Age lithics and Late Farming Community ceramics. Some decorated potsherds, one piece with three colours – red, blue/black and yellow. Few small fragments of flaked MSA lithics, made from felsic tuff and quartz. Found near a colluvial channel in brown-grey vertic soil associated with the land type Ea. Scatter is situated outside of the project footprint area, approximately 250 m north of the Topsoil Dump for Pit 1, and 400 m east of Pit 1. This scatter is 40 m from SA-022, situated in the same colluvial system.

Figure 5-21: View of Ceramic Scatter at FC-023 and Site Location

5.6.22 SA-024 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.86882 28.807345

A low density scatter of MSA flakes and flake fragments, made from felsic tuff. They are found in an area along a colluvial path, in calcrete-rich vertic colluvium. Large amount of

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gravel and calcrete nodules in the downwash. The scatter is situated approximately 120 m east of Pit 1 and 120 m north of the Topsoil Dump for Pit 1.

Figure 5-22: View of Stone Tools at SA-024 and Site Location

5.6.23 SA-025 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.868705 28.806603

Low density scatter containing small and medium sized MSA flakes and flake fragments and a few undecorated potsherds. Flakes are made from felsic tuff and quartz. Found in vertic soil associated with the land type Ea. The soil contains lots of debris and gravel. Scatter is 80 m from SA-024. It is situated 46 m from the eastern edge of the proposed Pit 1, and 160 m north of the Topsoil Dump for Pit 1.

Figure 5-23: View of Artefact Scatter at SA-025 and Site Location

5.6.24 FC-026 / Late Farming Community

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.868833 28.805546

Low density scatter of artefacts was found containing small undecorated potsherds, including some rim pieces, and some MSA stone flakes made from felsic tuff. One flake has

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some erratic retouch along one edge. The scatter appears to be at the end of a colluvial flow path on vertic soil associated with the land type Ea. This scatter is found in disturbed soil around a dirt road in proposed Pit 1.

Figure 5-24: View of Artefact Scatter at FC-026 and Site Location

5.6.25 SA-027 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.868788 28.798635

Few broken, unretouched stone flakes made from felsic tuff. There are a few small undecorated potsherds. Found in an area with vertic soils associated with the land type Ea. Situated 60 m from the proposed Lower Grade Stockpile development footprint, about 460 m east of the agricultural fields.

Figure 5-25: View of Flakes at SA-027 and Site Location

5.6.26 SA-028 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.869052 28.796542

Few individual broken, unretouched MSA flakes. Made from felsic tuff. Found in an area with vertic soils associated with the land type Ea. Situated within the proposed Lower Grade Stockpile area, about 260 m east of the

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agricultural fields.

Figure 5-26: View of Flake at SA-028 and Site Location

5.6.27 SA-029 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.871723 28.793433

A few broken MSA flakes found, some with erratic retouch on the edges. One radial core was found here. All stone tools are made from felsic tuff. Lithics were found on vertic soils associated with the land type Ea. Located within the proposed Low Grade Stockpile area, 150 m east of the agricultural fields.

Figure 5-27: View of Stone Tools at SA-029 and Site Location

5.6.28 SA-030 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.871685 28.79864

Few individual broken, unretouched, MSA flakes and flake fragments. All made from felsic tuff. Weathered and smoothed. None were photographed. Lithics were found on vertic soils associated with the land type Ea. This find spot is located within 195 m from the Low and Lower Grade Stockpile development

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footprints, and approximately 250 m west of Pit 1.

Figure 5-28: Site Location of SA-030

5.6.29 SA-031 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.871639 28.802708

Few individual unretouched, MSA flakes and flake fragments made from felsic tuff. Most were heavily weathered. None were photographed. Lithics were found on vertic soils associated with the land type Ea. This find spot is located within the proposed Pit 1 development footprint.

Figure 5-29: Site Location of SA-031

5.6.30 SA-032 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.871884 28.80426

Low density scatter of medium and small, complete and broken, unretouched MSA lithics. Most are made from felsic tuff and a few from quartz. Lithics are scattered over a 15 m area in disturbed soil around a dirt road. The soil is mostly vertic, associated with the land type Ea.

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The scatter is located within the proposed Pit 1 development footprint.

Figure 5-30: View of Stone Tools at SA-032 and Site Location

5.6.31 SA-033 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.871984 28.805887

A few broken, unretouched MSA flakes. Made of felsic tuff. None were photographed. Lithics were found on vertic soils associated with the land type Ea. Find spot is situated within the Topsoil Dump for Pit 1.

Figure 5-31: Site Location of SA-033

5.6.32 SA-034 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.870754 28.809044

Two MSA tools - one felsic tuff point with some unifacial retouch, one broken quartz flake. Found on vertic soil associated with the land type Ea. These stone tools were found near the base of Malokong Hill. This scatter is situated adjacent to the proposed Water Trench, approximately 40 m from the eastern edge of the Topsoil Dump for Pit 1

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Figure 5-32: View of Stone Tool at SA-034 and Site Location

5.6.33 FC-035 / Late Farming Community

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.869942 28.809537

Some potsherds and broken stone flakes found. None of the potsherds are decorated but one has some possible plant impressions. The few flakes found are made of felsic tuff or quartz. Artefacts are found in vertic soil associated with the land type Ea (as described in the specialist Soils Scoping Report), in a colluvial path. Located 30 m outside of the development footprint area, at the base of Malokong Hill. This find spot is about 100 m to the north east of SA-034 and 150 m to the south west of SA-022 and FC-023. All these spots are located within a colluvial system.

Figure 5-33: View of Potsherds at FC-035 and Site Location

5.6.34 SA-036 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.870894 28.811548

Low density scatter of MSA lithics, many broken and weathered. Some have retouch along two sides. Artefacts are found in an eroded, calcrete-rich colluvial path with vertic soils associated with the land type Ea.

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Scatter is situated 260 m to the east of the development footprint near the base of Malokong Hill. These artefacts are within the same colluvial system as the SA-019, SA-037 and SA- 049. It is about 120 m ‘downstream’ from SA-037 and 160 m from SA-019 and SA-049.

Figure 5-34: View of Stone Tools at SA-036 and Site Location

5.6.35 SA-037 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.871145 28.812595

Low density scatter of MSA lithics, many broken and weathered. Artefacts are found in an eroded, calcrete-rich colluvial path with vertic soils. Soil in the channel is a light grey and has a pebble and gravel component. Artefacts are found in and around the channel over a, roughly, 40 m squared area. Scatter is situated approximately 370 m to the east of the development footprint area near the base of Malokong Hill. It is about 80 m ‘downstream’ from SA-019 and 55 m away from SA-049.

Figure 5-35: View of Stone Tools at SA-037 and Colluvial Path

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

5.6.36 SA-038 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.879236 28.801511

Two stone flakes found along a dirt road. Irregular core and small irregular flake made from felsic tuff. Found in vertic clayey soil associated with the land type Ea. The dirt road is situated within the proposed Pit 1 area, approximately 100 m east of the eastern Pit 1 boundary.

Figure 5-36: View of Flake at SA-038 and Site Location

5.6.37 SA-039 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.879816 28.800595

A few isolated tools found with irregular and erratic retouch. Made from felsic tuff. No photographs taken. Found in vertic clayey soil associated with the land type Ea. Within the proposed Pit 1 area about 60 m an existing dirt road and 120 m from SA-038.

Figure 5-37: Site Location of SA-039

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

5.6.38 SA-040 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.88019 28.797611

Slight clearing in vegetation exposed a low density scatter of MSA tools. Some large flakes with irregular retouch were found. All tools were made with felsic tuff, a few are weathered. Found on vertic, clayey soil associated with the land type Ea (as described in the specialist Soils Scoping Report). Situated between the proposed Pit 1 and Waste Rock Dump development footprints.

Figure 5-38: View of Stone Tools at SA-040 and Site Location

5.6.39 SA-041 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.87991 28.790712

Clearing in vegetation revealed a low density scatter of MSA tools. Flakes made from felsic tuff, some heavily weathered. There are a few small, undecorated potsherds. Soil is a vertic, clayey soil associated with the land type Ea. Situated within the proposed Plant Area development footprint, about 100 m north east of old agricultural fields.

Figure 5-39: View of Scatter at SA-041 and Site Location

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

5.6.40 SA-042 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.8813 28.789866

Few, unretouched flakes found in a slight clearing in the vegetation. All made from felsic tuff. The soil is red and contains many small quartz and magnetite nodules. This find spot is within an old agricultural field, which explains the change of soil type. Situated within the proposed Plant Area development, about 180 m south of SA-041. This find spot is 320 m north east of the main road.

Figure 5-40: View of Scatter at SA-042 and Site Location

5.6.41 SA-043 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.882023 28.801441

Few small and broken flakes found. One with irregular retouch on one edge. Found in a clearing in the vegetation just before the dirt road. Flakes were found on vertic clayey soil, associated with the land type Ea. Situated within the proposed Pit 1 area, approximately 70 m from its eastern boundary.

Figure 5-41: View of Flake at SA-043 and Site Location

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

5.6.42 SA-044 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.898937 28.787599

Low density scatter of felsic tuff flakes. Some flakes are weathered. The soil is red and contains some small quartz and magnetite nodules. There is a change in vegetation and soil type (from vertic soil) suggesting that this land may have been used for agricultural fields historically. Scatter is situated within Lower Grade Stockpile development area. It is found about 75 m south of SA-045.

Figure 5-42: View of Flakes at SA-044 and Site Location

5.6.43 SA-045 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.898358 28.78803

Low density scatter of felsic tuff flakes. No retouch on the flakes, many broken fragments and some weathered. Clearing in vegetation exposed the flakes on red soil that contains quartz and magnetite nodules. Situated within the proposed Lower Grade Stockpile development area.

Figure 5-43: View of Stone Tools at SA-045 and Site Location

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

5.6.44 SA-046 – Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.913081 28.795732

Low density scatter of heavily weathered MSA lithics, none with retouch. Also found a few small, undecorated potsherds. Scatter is found in grey-brown vertic clayey soil, associated with the land type Ea. Situated within the proposed Pit 2 area, about 50 m from its southern edge. This scatter is about 70 m from SA-015.

Figure 5-44: View of Artefact Scatter at SA-046 and Site Location

5.6.45 SA-047 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.909348 28.795362

One felsic tuff tool with irregular bifacial retouch. Found on grey-brown vertic clayey soil, associated with the land type Ea. Found within the proposed Pit 2 area, about 70 m from its western boundary.

Figure 5-45: View of Stone Tool at SA-047 and Site Location

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

5.6.46 FC-048 / Late Farming Communities

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.896603 28.813229

Clearing on and around a natural, horizontal rock surface with some large boulders around it. Vegetation is grassy and less bushy around the clearing. This is distinctly different from the surrounding vegetation, which are very dense thorn bush, Sickle Bush and grass. The area has been used recently for a fire. A few potsherds were found, one with decoration. Soil in the area is vertic brown, clayey soil associated with the land type Ea (as described in the specialist Soils Scoping Report). Situated within the proposed Tailings Dam development footprint, 200 m from an existing dirt road.

Figure 5-46: View of Potsherd and Site at FC-048

5.6.47 SA-049 / Stone Age

Field Rating: Co-ordinates Cultural Significance: Negligible Grade IV C -23.871406 28.813108

Low density scatter of MSA flakes, broken flakes, and cores. Some with irregular retouch and others weathered. There are a few small, undecorated potsherds. Scatter is found along a clear eroded colluvial channel in gravel-rich calcrete. It is near to (and possibly associated with) other scatters - it is situated 60 m north of SA-019, and SA-037 is 60 m further down the hill (to the west). Situated 450 m outside of the development footprint area, near the base of Malokong Hill.

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Figure 5-47: View of Stone Tools at SA-049 and Site Location

6 Sensitivity Analysis and No-Go Area A sensitivity analysis of the proposed Magnetite Project was completed pre-scoping based on information contained in the literature review (See HSR). The results of the literature review and brief screening assessment indicated that the hills and ridges within the region are of high sensitivity. These types of topographical features were commonly settled by Late Farming Communities through to the historical period. As shown in the in the HSR, the area under consideration is located within the historic Bakenberg Location where several archaeological and historic stonewalled sites were identified. These included Hendrik Masibi’s historic early 20th century capital, and Malakong Hill on the eastern border of the project area. In addition to the hills and ridges, agricultural fields were highlight with a medium to high sensitivity. Based on experience on similar project in the region, agricultural field are commonly associated with burial grounds and graves. The sensitivity analysis was used to inform the project design and amend the development footprint as far as was feasible to minimise negative impacts on heritage resources. Through this process, the project infrastructure was amended where the Tailings Dam and Plant areas were altered to avoid Malokong Hill. The amended development footprint is presented in Plan 1 represents the first amendment to the project design. Reconnaissance of the project area was undertaken on the first amended development footprint. The results of the reconnaissance are presented in Section 5.6 above and Plan 2.

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U Plan 1 B E DU WAN D A Proposed Infrastructure RevisedNE Proposed InfrastructureM WA D NOT 355 SE 2 NOT 355 SE 2 Pamish Investments

Magnetite Mine EIA

Heritage Sensitivity Analysis

Ga-Mokwena Ga-Mokwena

Legend

Project Area (10 100 ha) Taolome Taolome Settlement

Main Road

Minor Road Malokong Malokong

Pudiakagopa Pudiakagopa Track

Non-Perennial Stream

Perennial Stream Dam Wall Haakdoring Haakdoring Dam / Lake Moshate Bakenberg Moshate Bakenberg Rooivaal Top Soil Rooivaal Traditional Traditional Non-Perennial Pan / Stream Council Tailings Council Dump Waste Rock Dump Option 1 Dams 29 ha Malokongskop Waste Malokongskop 169 ha 124 ha Heritage Sensitivity Rock Dump Mothoathoase Mothoathoase 220 ha Grave Site (High) Pit 1 Pit 1 Basogadi Basogadi 129 ha 129 ha Iron Age Feature (High)

Plant Iron Age Site (High) Area Tailings Waste Rock 236 ha Dams Plant Iron Age Surface Occurence (High) Kaditshwene Dump Option 2 Kaditshwene 69 ha Area Ditlotswana Ditlotswana 161 ha 62 ha Middle Stone Age (High) Pit 2 Pit 2 66 ha 66 ha Ridges, 200 m Buffer of Ridges (High)

Agricultural Fields - Potential Graves (Medium to High) Sepharane Sepharane 50 m Buffer of Streams - Potential of Stone Age Wash (Medium to Low) Paleo Sensitivity (High)

Mapela Mapela Traditional Traditional

Council Council

Sustainability Service Positive Change Professionalism Future Focused Integrity

Projection: Transverse Mercator Ref #: scm.VMC3049.201506.157 R Datum: WGS 1984 Revision Number: 1 E Legend IV R 5 Central Meridian: 29°E Date: 18/06/2015 I RI 1

R R Berm E T E T S S 0 1 2 4 6 Legend Haul Road Kilometres Proposed Infrastructure Proposed Infrastructure K 8 1:110 000

www.digbywells.com © Digby Wells Environmental

28°47'0"E 28°48'0"E 28°49'0"E 28°50'0"E

SA-006 Plan 2

128.9 ha FC-023 Pamish Investments

SA-025 SA-024 SA-022 SA-021 RO 1 ha BO Magnetite Mine EIA FC-035 SA-020 Identified Heritage FC-018 SA-034 SA-036 SA-037 59.5 ha Resources 23°52'0"S SA-007 SA-006 23°52'0"S SA-049 SA-019 SA-033 SA-028 SA-027 FC-026 FC-023 SA-022 SA-004 Legend 32.1 ha SA-020 Malokongskop FC-035 SA-036 SA-005 SA-034 SA-029 SA-030 SA-031 Project Area SA-033 SA-049

FC-003 70.5 ha SA-019 SA-009 SA-032 SA-005 SA-004 Settlement SA-010 FC-003 Main Road

32.1 Mothoathoase Minor Road 1 ha ha Track

SA-038

SA-041 4 ha SA-039 Non-Perennial Stream 12.3 ha SA-040

SA-042 Dam Wall

7.6 ha SA-043 FC-011 Basogadi Dam / Lake FC-002 23°53'0"S SA-012 23°53'0"S Identified Heritage Resources 128.9 ha

Farming Community Infrastructure 3.8 ha Access Point Stone Age

Dirty Water Trench (17128 m) Heritage Tracks

60 ha Fence (18103 m) Burial Ground & Graves

Perimeter Fence (16478 m) Farming Community

1 ha Pipeline (8100 m)

Site Road (25504 m)

FC-048 1.5 ha 43.5 ha Solution Trench (3557 m) SA-013 0.1 ha SA-045 62.1 ha Storm Water Trench (12732 m)

SA-044 FC-014 Contractor's Camp (7.6 ha) 23°54'0"S 23°54'0"S

7.5 ha Low Grade Stockpile (130.5 ha) 65.8 ha

1 ha Lower Grade Stockpile (103 ha)

Ditlotswana PCD (4 ha)

8

ha Pit 1 (128.9 ha)

Pit 2 (65.8 ha)

SA-047 Plant Area (12.3 ha)

Return Water Dam (0.1 ha) Sustainability Service Positive Change Professionalism Future Focused Integrity SA-016 BGG-001 Projection: Transverse Mercator Ref #: scm.VMC3049.201506.158 SA-015 Stormwater Dam (5.3 ha) Datum: WGS 1984 Revision Number: 2 Central Meridian: 29°E Date: 29/06/2015 SA-046 Tailings Dam (62.1 ha)

Topsoil Stockpile (40.1 ha) 0 0.25 0.5 1

Waste Rock Dump (11.5 ha) Kilometres 23°55'0"S 23°55'0"S 1:25 000

www.digbywells.com © Digby Wells Environmental 28°47'0"E 28°48'0"E 28°49'0"E 28°50'0"E

Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

7 Heritage Impact Assessment

7.1 Methodology

7.1.1 Evaluation of Significance The significance rating process is designed to provide a numerical rating of the cultural significance7 of identified heritage resources. The evaluation was done as objectively as possible through a matrix developed by Digby Wells for this purpose. In addition, the methodology aims to allow ratings to be reproduced independently should it be required, provided that the same information sources are used. This matrix takes into account heritage resources assessment criteria set out in subsection 3(3) of the NHRA (see Box 2), which determines the intrinsic, comparative and contextual significance of identified heritage resources. A resource’s importance rating is based on information Value = Importance x Integrity obtained through review of available credible sources where and representivity or uniqueness (i.e. known examples of Importance = average sum similar resources to exist). The final significance of attributed to a resource furthermore takes into account Aesthetic + Historic + Scientific + Social the physical integrity of the fabric of the resource. The formula used to determine significance can is Box 3: CS formula summarised in Box 3. The rationale behind the heritage value matrix takes into account the fact that a heritage resource’s value is a direct indication of its sensitivity to change (impacts). Value therefore needs to be determined prior to the completion of any assessment of impacts. This matrix rates the potential, or importance, of an identified resource relative to its contribution to certain values – aesthetic, historical, scientific and social. The significance of a resource is directly related to the impact on it that could result from project-related activities, as it provides minimum accepted levels of change to the resource. SAHRA has published minimum standards that include minimum required mitigation of heritage resources. These minimum requirements are integrated into the matrix to guide both assessments of impacts and recommendations for mitigation and management of resources. The weight assigned to the various parameters for significance in the formula, significance ratings and recommended mitigation are presented in Table 7-1.

7 Cultural significance is defined in the NHRA as the intrinsic “aesthetic, architectural, historical, scientific, social, spiritual, linguistic or technological value or significance” of a heritage resource. These attributes are combined and reduced to four themes used in the Digby Wells significance matrix: aesthetic, historical, scientific and social.

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

7.1.2 Field Ratings Although grading of heritage resources remains the responsibility of heritage resources authorities, SAHRA requires in terms of its Minimum Standards that heritage reports include Field Ratings for identified resources to comply with section 38 of the NHRA. The NHRA in terms of section 7 provides for a system of grading of heritage resources that form part of the national estate, distinguishing between three categories.

The field rating process is designed to provide a numerical rating of the recommended grading of Field Rating = average sum identified heritage resources. The evaluation was done of as objectively as possible by integrating the field rating Aesthetic + Historic + Scientific + Social into the significance matrix. Field ratings guide decision- making in terms of appropriate minimum required Box 4: Field rating formula mitigation measures and consequent management responsibilities in accordance with section 8 of the NHRA. The formula used to determine field ratings is summarised in Box 4. The weight assigned to the various field rating parameters in the formula and the sum of the average ratings are is presented in Table 7-1.

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Table 7-1: Ratings and Descriptions used in Determining CS and Field Ratings

IMPORTANCE INTEGRITY FIELD RATING Rating A heritage resource’s contribution to aesthetic, historic, scientific The undivided or unbroken state, material wholeness, Recommended grading of identified heritage resources in terms of and social value. completeness or entirety of a resource or site NHRA Section 7

Not assessed - dimension and/or attribute not considered in determining - Not assessed - dimension and/or attribute not considered in field rating. value.

The resource exhibits attributes that may be considered in a particular No information potential, complete loss of meaning, Fabric completely 0 dimension, but it is so poorly represented that it cannot or does not degraded, original setting lost contribute to the resource’s overall value.

Fabric poorly preserved, limited information, little meaning ascribed, Resources under general protection in terms of NHRA sections 34 to 37 1 Common, well represented throughout diverse cultural landscapes extensive encroachment on setting with Negligible significance

Generally well represented but exhibits superior qualities in comparison to Fabric is preserved, some information potential (quality questionable) Resources under general protection in terms of NHRA sections 34 to 37 2 other similar examples and meaning evident, some encroachment on setting with Low significance

The resource exhibits attributes that are rare and uncommon within a Fabric well preserved, good quality information and meaning evident, Resources under general protection in terms of NHRA sections 34 to 37 3 region. It is important to specific communities. limited encroachment with Medium to Medium-High significance

Excellent preservation of fabric, high information potential of high Resources under general protection in terms of NHRA sections 34 to 37 4 Rare and uncommon, value of national importance quality, meaning is well established, no encroachment on setting with High significance

The resource exhibits attributes that are considered singular, unique Resources under general protection in terms of NHRA sections 34 to 37 5 and/or irreplaceable to the degree that its significance can be universally with Very High significance accepted. Heritage resources under formal protection that can be considered to 6 have special qualities which make them significant within the context of a province or a region Heritage resources under formal protection that can be considered to 7 have special qualities which make them significant within a national and / or international context.

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

7.1.3 Impact Assessment The potential impacts were considered through an examination of the project phase and activity, the environmental aspect, the interdependencies between aspects, an assessment and classification of categories, and consideration of the potential impact on heritage resources.

7.1.3.1 Defining Heritage Impacts Different heritage impacts may manifest in different geographical areas and diverse communities. For instance, heritage impacts can simultaneously affect the physical resource and have social repercussions: this is compounded when the intensity of physical impacts and social repercussions differ significantly. In addition, heritage impacts can influence the cultural significance of heritage resources without any actual physical impact on the resources taking place. Heritage impacts can therefore generally be placed into three broad categories (adapted from Winter & Bauman 2005: 36): ■ Direct or primary heritage impacts affect the fabric or physical integrity of the 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. ■ Indirect, induced or secondary heritage impacts can 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 of its cultural significance that may be dependent on ritual patterns of access. Although the physical fabric of the resource is not affected through any primary impact, its significance is affected that can ultimately result in the loss of the resource itself. ■ Cumulative heritage impacts result from in-combination effects on 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 particular resource at the same time, e.g. the effect of regular blasting activities on a nearby rock art site or protected historical building high. . 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.

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

. 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.

The relevance of the above distinction to defining the study areas in the HSR arises from the fact that heritage resources do not exist in isolation to the wider natural, social, cultural and heritage landscape: cultural significance is therefore also linked to rarity / uniqueness, physical integrity and importance to diverse communities. In addition, the NHRA requires that heritage resources are graded 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 are discussed in detail in the HSR.

7.1.3.2 Impact Assessment The impact rating process is designed to provide a numerical rating of the identified heritage impacts. The significance rating follows an established impact/risk assessment formula is shown in Box 5. The weight assigned to the various parameters for positive and negative impacts in the formula is presented in Table 7-3 below. Project-related impacts on heritage resources have taken into account the inherent value of heritage resources, described above, and only applied to resources with values above negligible. As a result, the impact assessment did not consider individual resources, but was applied to diverse resources grouped in terms of similar values. The magnitude will then be applied to pre- and post- Significance = consequence of an event x probability of the event occurring mitigation scenarios with the where: intention of removing all Consequence = type of impact x (Intensity + Spatial Scale + Duration) impacts on heritage and resources. Where project related mitigation does not Probability = Likelihood of an impact occurring avoid or sufficiently reduce In the formula for calculating consequence: negative changes/impacts on Type of impact = +1 (positive) or -1 (negative) heritage resources with high values, mitigation of these Box 5: Impact assessment formula resources may be required. This may include alteration, restoration or demolition of structures under a permit issued by the HRAs.

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Impacts were rated prior to mitigation and again after consideration of the proposed mitigation measures. Impacts were then categories into one of eight categories listed in Table 7-3. The relationship between the consequence, probability and significance ratings is also graphically depicted in Table 7-3.

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Table 7-2: Description of Duration, Extent, Intensity and Probability Ratings used in Impact Assessment

PROBABILITY RATING EXTENT RATING INTENSITY RATING DURATION RATING A measure of the chance that consequences of that A measure of how wide the impact would A measure of the degree of harm, injury or Value A measure of the lifespan of the impact selected level of severity could occur during the occur loss. exposure window.

Probability Description Exposure Description Intensity Description Probability Description Impacts on heritage Happens frequently. Impact will permanently alter resources will have The impact will occur or change the heritage international repercussions, Major change to Heritage regardless of the 7 Permanent resource and/or value International issues or effects, i.e. in Extremely high Resource with High-Very Certain/Definite implementation of any (Complete loss of context of international High Value preventative or corrective information) cultural significance, actions. legislation, associations, etc.

Impacts on heritage

resources will have national Impact will reduce over time repercussions, issues or Moderate change to Heritage Happens often. after project life (Mainly 6 Beyond Project Life National effects, i.e. in context of Very high Resource with High-Very High probability It is most likely that the renewable resources and national cultural High Value impact will occur. indirect impacts) significance, legislation, associations, etc.

Impacts on heritage

resources will have

provincial repercussions, Minor change to Heritage The impact will cease after Could easily happen. 5 Project Life Region issues or effects, i.e. in High Resource with High-Very Likely project life. The impact may occur. context of provincial cultural High Value 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.

Impacts on heritage Has not happened yet, but

resources will have local Moderate change to Heritage could happen once in a Impact will remain for >10% - Unlikely / Low 3 Medium Term Local repercussions, issues or Moderate Resource with Medium - lifetime of the project. 50% of Project Life probability effects, i.e. in context of the Medium High Value There is a possibility that the local study area. impact will occur.

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

PROBABILITY RATING EXTENT RATING INTENSITY RATING DURATION RATING A measure of the chance that consequences of that A measure of how wide the impact would A measure of the degree of harm, injury or Value A measure of the lifespan of the impact selected level of severity could occur during the occur loss. exposure window.

Probability Description Exposure Description Intensity Description Probability Description

Conceivable, but only in

extreme circumstances.

Have not happened during Impacts on heritage the lifetime of the project, but resources will have site Minor change to Heritage has happened elsewhere. Impact will remain for <10% specific repercussions, 2 Short Term Limited Low Resource with Medium - Rare / Improbable The possibility of the impact of Project Life issues or effects, i.e. in Medium High Value materialising is very low as a context of the site specific result of design, historic study area. experience or implementation of adequate mitigation measures

Impact may be Impacts on heritage No change to Heritage sporadic/limited duration and resources will be limited to Resource with values can occur at any time. E.g. the identified resource and Expected never to happen. 1 Transient Very Limited Very low medium or higher, or Any Highly Unlikely /None Only during specific times of its immediate surroundings, Impact will not occur. change to Heritage Resource operation, and not affecting i.e. in context of the specific with Low Value heritage value. heritage site.

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Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Table 7-3: Impact Significance Ratings, Categories and Relationship between Consequence, Probability and Significance

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.

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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7.2 Risk versus Impact Risk is defined as the potential consequence(s) of an interaction combined with its likelihood. Should a risk eventuate, it will manifest as an impact. These concepts are often misconstrued and lead to disproportionate amounts of effort spent on assessing minor risks with potentially insignificant impacts, at the cost of overlooking more important ones. The identification of project risks should take place during the scoping phase of the ESIA. This allows for input from stakeholders prior to commencement of the impact assessment phase. Example: The presence of vehicles on a site obviously creates the potential for hydrocarbon spills, but it cannot be seen as a foregone conclusion. Therefore hydrocarbon spillage is treated as a risk, as it has not yet eventuated. Risks include: ■ Hydrocarbon spills from vehicles and machinery; ■ Spills or leaks from pipelines, storage areas, berms and channels etc.; and ■ Increased crime and breakdown of social order.

Broad mitigation measures and monitoring were provided for low risks and unplanned events, however, they were not assessed in detail (i.e., with significance ratings). In general monitoring is an accepted form of mitigation for low risks.

7.3 Cultural Significance The CS assigned to identify heritage resources is summarised in Table 7-4 and presented in detail in Table 7-5 below (Refer to Section 3 for rationale). The assessment of the cultural significance of identified heritage resources takes into consideration criteria as defined under Section 3(3) of the NHRA. These dimensions include aesthetic & technical criteria, historical importance & associations, information potential, and social criteria. The Statement of Significance indicated that the identified heritage resources designation range from negligible to very high significance.

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Table 7-4: Summary of Identified Heritage Resources Grading and Significance

Grading & Significance No. of Sites

Grade III B 1

High 1

General Protection IV A 3

Very High 1

Low 2

General Protection IV B 1

Negligible 1

General Protection IV C 42

Negligible 42

Grand Total 47

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Table 7-5: Cultural Significance of Identified Heritage Resources

Cultural Field Longitud Resource ID Type Description Significanc CS Motivation Field Rating Motivation Mitigation Latitude Rating e e

The cemetery is located well outside the

prescribed buffer for blasting and vibrations.

Nevertheless, it is recommended that Cemetery located 600m outside known burial grounds and graves be of the development footprint. Burial grounds and graves monitored during the operational phase to Burial grounds and graves are General 7331/BGG- are generally protected record and mitigate any indirect impacts on Burial / grave Cemetery Very High inherently sensitive where the Protection -26.335908 29.241685 001 under Section 36 of the the resource. In addition, it is recommended social significance of these IV A NHRA. that Chance Find Protocols be developed resources is universally for the accidental discovery of burial accepted. grounds and graves during the construction and operational phases of the Magnetite Project

Large stonewalled settlement Settlement is largely intact with walling primarily intact. with high integrity. Historic Stonewalling demonstrates associations with Langa Indirect impacts during the operational great technical skill contributing communities surrounding phase may occur. Potential damage to the to aesthetic character. Late Farming Farming Community / Grade III Malokong Hill is high, sites through blasting activities necessitates 7331/FC-002 High Information potential from the -26.335951 29.241455 Community site Historic Settlement B contributing to the cultural the detailed recording of the site through site is high. Historical landscape of the region. archaeological mitigations and mapping to associations to Langa history Significance in the preserve the site through record. well-established, consequently localised context is well social aspects associated with established. descendant community/ies.

Stonewalled settlement on General Late Farming Farming Community / Encroachment to the site 7331/FC-003 Low Malokong Hill primarily intact. Protection -26.335908 29.241319 Community site Historic Settlement has lessened the integrity Indirect impacts during the operational Historical association to Langa IV A of the site. Association with phase may occur. Potential damage to the history well established, settlement on Malokong sites through blasting activities necessitates consequently social aspects Hill and Langa the detailed recording of the site through with descendent community/ies. General Late Farming Farming Community / communities is high. Site is archaeological mitigations and mapping to 7331/FC-018 Low Information potential is lower as Protection -26.346515 29.270643 Community site Historic Settlement generally protected under preserve the site through record. encroachment has lessened the IV A Section 35 of the NHRA integrity of the site General Few MSA flakes and flake Isolated find spot / scatter Integrity of the find spot / 7331/SA-004 Occurrence Negligible outside of primary context. Protection scatter indicates that the -23.872497 28.81271 fragments No further mitigation is required on the Identified resources can be IV C fabric of the site is individual resources as it has been considered in terms of the General completely degraded and Two isolated MSA flake sufficiently recorded. 7331/SA-005 Occurrence Negligible technical skill of manufacture, Protection the original setting is lost. -23.8731681 28.810916 fragments but is poorly represented that IV C Resource is generally

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Cultural Field Longitud Resource ID Type Description Significanc CS Motivation Field Rating Motivation Mitigation Latitude Rating e e

limited scientific information can General protected under Section 35 Low density Stone Age 7331/SA-006 Occurrence Negligible be collected. Protection of the NHRA. -26.334081 29.238646 concentration IV C

General Low density Stone Age 7331/SA-007 Occurrence Negligible Protection -26.333778 29.238711 concentration IV C

General Low density Stone Age 7331/SA-009 Occurrence Negligible Protection -26.333655 29.238899 concentration IV C

General Low density Stone Age 7331/SA-010 Occurrence Negligible Protection -26.331953 29.238537 concentration IV C General

7331/FC-011 Occurrence Low density ceramic scatter Negligible Protection -26.344883 29.245927

IV C

General Low density Stone Age 7331/SA-012 Occurrence Negligible Protection -26.348685 29.240802 concentration IV C Isolated find spot / scatter Integrity of the find spot / General Low density Stone Age outside of primary context. scatter indicates that the 7331/SA-013 Occurrence Negligible Identified resources can be Protection fabric of the site is -26.334592 29.250261 concentration No further mitigation is required on the considered in terms of the IV C completely degraded and individual resources as it has been technical skill of manufacture, the original setting is lost. General sufficiently recorded. 7331/FC-014 Occurrence Isolated potsherd Negligible but is poorly represented that Protection Resource is generally -26.334464 29.250652 limited scientific information can IV C protected under Section 35 be collected. of the NHRA. General 7331/SA-015 Occurrence Isolated Stone Age Flake Negligible Protection -26.341129 29.243421 IV C

General Low density Stone Age 7331/SA-016 Occurrence Negligible Protection -26.340704 29.243016 concentration IV C General Few MSA flakes and flake Isolated find spot / scatter Integrity of the find spot / 7331/SA-019 Occurrence Negligible outside of primary context. Protection scatter indicates that the -23.871836 28.812772 fragments No further mitigation is required on the Identified resources can be IV C fabric of the site is individual resources as it has been considered in terms of the General completely degraded and Few MSA flakes and flake sufficiently recorded 7331/SA-020 Occurrence Negligible technical skill of manufacture, Protection the original setting is lost. -23.870107 28.812971 fragments but is poorly represented that IV C Resource is generally

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Cultural Field Longitud Resource ID Type Description Significanc CS Motivation Field Rating Motivation Mitigation Latitude Rating e e

limited scientific information can General protected under Section 35 Few MSA flakes and flake 7331/SA-021 Occurrence Negligible be collected. Protection of the NHRA. -23.869276 28.812199 fragments IV C

General Low density MSA 7331/SA-022 Occurrence Negligible Protection -23.868844 28.810585 concentration IV B

General Low density ceramic scatter 7331/FC-023 Occurrence Negligible Protection -23.86881 28.810236 and MSA concentration IV C

General Low density MSA 7331/SA-024 Occurrence Negligible Protection -23.86882 28.807345 concentration IV C Low density MSA General 7331/SA-025 Occurrence concentration with ceramic Negligible Protection -23.868705 28.806603 sherds IV C General Low density ceramic scatter 7331/FC-026 Occurrence Negligible Protection -23.868833 28.805546 and MSA concentration IV C General Few MSA flakes and flake 7331/SA-027 Occurrence Negligible Protection -23.868788 28.798635 fragments IV C

General Few MSA flakes and flake 7331/SA-028 Occurrence Negligible Isolated find spot / scatter Protection Integrity of the find spot / -23.869052 28.796542 fragments outside of primary context. IV C scatter indicates that the Identified resources can be fabric of the site is General No further mitigation is required on the Few MSA flakes and flake considered in terms of the completely degraded and 7331/SA-029 Occurrence Negligible Protection individual resources as it has been -23.871723 28.793433 fragments technical skill of manufacture, the original setting is lost. IV C sufficiently recorded but is poorly represented that Resource is generally limited scientific information can General protected under Section 35 Few MSA flakes and flake 7331/SA-030 Occurrence Negligible be collected. Protection of the NHRA. -23.871685 28.79864 fragments IV C

General Few MSA flakes and flake 7331/SA-031 Occurrence Negligible Protection -23.871639 28.802708 fragments IV C

General Low density MSA 7331/SA-032 Occurrence Negligible Protection -23.871884 28.80426 concentration IV C

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Cultural Field Longitud Resource ID Type Description Significanc CS Motivation Field Rating Motivation Mitigation Latitude Rating e e General Two isolated MSA flake 7331/SA-033 Occurrence Negligible Protection -23.871984 28.805887 fragments IV C

General Two isolated MSA flake 7331/SA-034 Occurrence Negligible Protection -23.870754 28.809044 fragments IV C Isolated find spot / scatter Integrity of the find spot / outside of primary context. General scatter indicates that the 7331/FC-035 Occurrence Low density ceramic scatter Negligible Identified resources can be Protection fabric of the site is -23.869942 28.809537 No further mitigation is required on the considered in terms of the IV C completely degraded and individual resources as it has been technical skill of manufacture, General the original setting is lost. Low density MSA sufficiently recorded 7331/SA-036 Occurrence Negligible but is poorly represented that Protection Resource is generally -23.870894 28.811548 concentration limited scientific information can IV C protected under Section 35 be collected. of the NHRA General Low density MSA 7331/SA-037 Occurrence Negligible Protection -23.871145 28.812595 concentration IV C

General Two isolated MSA flake 7331/SA-038 Occurrence Negligible Protection -23.879236 28.801511 fragments IV C General Few MSA flakes and flake 7331/SA-039 Occurrence Negligible Protection -23.879816 28.800595 fragments IV C

General Low density MSA 7331/SA-040 Occurrence Negligible Protection -23.88019 28.797611 concentration IV C Isolated find spot / scatter Integrity of the find spot / General Low density MSA outside of primary context. scatter indicates that the 7331/SA-041 Occurrence Negligible Identified resources can be Protection fabric of the site is -23.87991 28.790712 concentration No further mitigation is required on the considered in terms of the IV C completely degraded and individual resources as it has been technical skill of manufacture, General the original setting is lost. Few MSA flakes and flake sufficiently recorded 7331/SA-042 Occurrence Negligible but is poorly represented that Protection Resource is generally -23.8813 28.789866 fragments limited scientific information can IV C protected under Section 35 be collected. of the NHRA General Few MSA flakes and flake 7331/SA-043 Occurrence Negligible Protection -23.882023 28.801441 fragments IV C

General Low density MSA 7331/SA-044 Occurrence Negligible Protection -23.898937 28.787599 concentration IV C

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Cultural Field Longitud Resource ID Type Description Significanc CS Motivation Field Rating Motivation Mitigation Latitude Rating e e General Low density MSA 7331/SA-045 Occurrence Negligible Protection -23.898358 28.78803 concentration IV C

General Low density MSA 7331/SA-046 Occurrence Negligible Isolated find spot / scatter Protection Integrity of the find spot / -23.913081 28.795732 concentration outside of primary context. IV C scatter indicates that the Identified resources can be fabric of the site is General No further mitigation is required on the considered in terms of the completely degraded and 7331/SA-047 Occurrence One isolated MSA flake Negligible Protection individual resources as it has been -23.909348 28.795362 technical skill of manufacture, the original setting is lost. IV C sufficiently recorded but is poorly represented that Resource is generally limited scientific information can General protected under Section 35 Late Farming Possible historic site with 7331/FC-048 Negligible be collected. Protection of the NHRA -23.896603 28.813229 Community site isolated ceramic sherd IV C

General Low density MSA 7331/SA-049 Occurrence Negligible Protection -23.871406 28.813108 concentration IV C

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7.4 Impact Assessment This chapter considers the potential direct and indirect impacts on heritage resources identified within the development footprint of the Magnetite Project, as well as those within the greater surrounding landscape. These impacts are considered in relation to the project related activities outlined in the Scoping Report. The impact assessment and mitigations measures chapter is as a narrative description of the sources of risk and potential impacts, and as a discussion of feasible mitigation measures to avoid and/or better negative impacts and enhance positive one. The proposed activities for which environmental authorisation are being applied for correspond to Listing Notices GNR 983, 984 and 985. Detailed descriptions were provided in the Scoping Report and summarised in Table 7-6 below. Table 7-6: Project Activities

Construction

Site clearance and vegetation removal;

Change of land-use from agriculture to mining;

Topsoil and softs removal and stockpiling;

Development of access and haul roads;

Surface infrastructure development such as stormwater channels, bridges, dams, offices and workshops.

Water abstraction and use;

Waste generation, storage and disposal (hazardous and general);

Use of heavy machinery (Haul Trucks, FEL, Excavators etc.)

Employment and capital expenditure;

Operation

Development of two open pits by drilling and blasting, truck and shovel methods;

Development of one waste rock dump;

Concentrator plant including crushing, grinding and screening;

Conveyor belts at crushing and grinding sections and for concentrate product and tailings;

Hauling of waste rock;

Tailings Storage Facility (TSF);

Pollution control dam, water storage dam and associated pipelines;

Stormwater diversion berms and channels;

Storage of fuels, process concentrate, maintenance/workshop oils, and explosive storage facilities;

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Waste generation, storage and disposal (hazardous and general);

Product storage (magnetite concentrate);

Sewerage treatment plant;

Use of heavy machinery (Haul trucks, FEL, Excavators etc.)

Employment and operational expenditure;

Closure and Rehabilitation

Dismantling and removal of major equipment and infrastructure

Waste generation, storage and disposal

Rehabilitation of disturbed areas including stockpile dumps and pits etc.

Backfilling of the open pits using waste rock only.

Post-closure monitoring

7.4.1 Direct Impacts on Stone Age Resources No intrusive sampling was undertaken as part of this assessment. The assessment of the cultural significance was based on the individual Stone Age heritage resources identified during reconnaissance. Scattered surface occurrences of MSA stone tools were identified across the Magnetite Project development footprint. The cultural significance assessment of these individual finds considered the artefacts in terms of the aesthetic and scientific criteria as defined under Section 3. Specifically these criteria considered: ■ The degree of technical skill at a particular period; ■ The possession of uncommon or rare cultural heritage aspects; ■ The information potential; and ■ The importance of demonstrating principle characteristic.

The identified accumulations comprised of isolated find spots and low-density scatters in visibly disturbed areas, for example road clearings, borehole and prospecting sites, agricultural fields and distinct colluvial paths. No habitation or factory Stone Age sites were identified. Over 95% of the identified stone tools were made of felsic tuff – a fine grained raw material – originating from the Rooiberg Group formation roughly 40 km from the study area. This may serve as an indicator of long-distance raw material transportation by MSA tool producers or the geofluvial processes in the rivers and tributaries in the region. Geomorphic processes associated with vertic soils, as discussed under Section 5.3, also provide an explanation for the distribution of the accumulations within the development footprint. Here, the coarse elements in the soil, such as rock fragments, cannot be fragmented and are pushed towards the soil surface through a pressure process known as slickenside, often getting deposited on the surface.

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Considering the Stone Age artefacts within the fluvial and geomorphic processes occurring in the area demonstrate that none of the material is in its primary context. Material is likely to have been spread around the landscape through various colluvial and fluvial processes (in Pit 1, the Waste Rock Dump site and the Plant Area). This includes the specific fluvial processes of the Mogalakwena River and its tributaries affecting horizontal artefact redistribution around the landscape, and the nature of the vertic soils affecting vertical distribution. Based on this understanding, the identified accumulations were assigned a negligible significance value. The impact assessment for these resources indicates that the Magnetite Project will result in a minor negative impact and that no further mitigation is required. However, through this assessment a minor indirect positive impact has occurred as the heritage resources have been recorded and are preserved through documentation. Project related activities during both the construction and operational phases of the project will have a direct negative impact on the identified Stone Age accumulations with a negligible significance. These include MSA accumulations as summarised below: Table 7-7: Identified Stone Age Accumulations with Negligible Significance

7331/S 7331/S 7331/S 7331/S 7331/S 7331/S 7331/S 7331/S 7331/S 7331/S A-004 A-009 A-015 A-021 A-027 A-031 A-036 A-040 A-044 A-049

7331/S 7331/S 7331/S 7331/S 7331/S 7331/S 7331/S 7331/S 7331/S A-005 A-010 A-016 A-022 A-028 A-032 A-037 A-041 A-045

7331/S 7331/S 7331/S 7331/S 7331/S 7331/S 7331/S 7331/S 7331/S A-006 A-012 A-019 A-024 A-029 A-033 A-038 A-042 A-046

7331/S 7331/S 7331/S 7331/S 7331/S 7331/S 7331/S 7331/S 7331/S A-007 A-013 A-020 A-025 A-030 A-034 A-039 A-043 A-047

The activities considered are: ■ Site clearance, topsoil and vegetation removal; ■ Development and use of access; ■ Construction of infrastructure; and ■ Development and operation of opencast pits, waste rock dumps and tailings;

Individually, these resources have been sufficiently recorded and no further mitigation is required. However, in light of the number of MSA accumulations identified during reconnaissance, there is sufficient evidence to indicate that a Stone Age Landscape is present within the Magnetite Project study area. As previously stated, this assessment is

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based on surface observations as necessary permits required under Section 35(4) of the NHRA for intrusive sampling were not held. Table 7-8: Significance Ratings for the Stone Age Landscape of the Study Area

Resource Significan Type Description CS Motivation ID ce

A significant number of individual

accumulations were identified within

the study area to suggest that a Stone Age Cultural Low density MSA Stone Age Landscape is present. Low Landscape landscape concentration The scientific potential suggest that scientific information potential exists if subsurface distributions are better understood

The activities considered will have bearing on the heritage aspect. The identified issue and resultant impact will be the physical alteration of the land, resulting in the potential damage to and/or destruction of the Stone Age Landscape. An impact assessment for the damage to and/or destruction of the Stone Age Landscape based on the reasoning presented above is summarised in Table 7-9. Table 7-9: Summary of Impact Assessment related to the Damage and/or Destruction of the Stone Age Landscape

IMPACT DESCRIPTION: Alteration to Stone Age Landscape in development footprint Predicted for project Pre-construction Construction Operation phase: Dimension Rating Motivation PRE-MITIGATION

Activities during the pre-

construction, construction and

Duration Permanent (7) operational phases will

permanently alter the Stone

Age Landscape

Consequence: The extent will extend to most Moderately or all of the Stone Age Significance: Extent Local (3) detrimental (-11) accumulations associated with Moderate - negative the study area (-77)

Intensity x The intensity is characterised type of Very low - negative (-1) as any change to a resource impact with low significance

It is certain that project related activities will Probability Certain (7) permanently alter the Stone Age Landscape MITIGATION: The Stone Age Landscape should be mitigated through detailed recording that may include sampling by augering or Shovel Test Pits (STPs) to establish if subsurface deposit exists within the development footprint. The proposed mitigation measures will require a NHRA section 35 Permit issued by SAHRA to a qualified archaeologist. While proposed mitigation measures are intrusive, they will preserve identified resources through record and contribute to the

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understanding of the Stone Age Landscape of the study area.

POST-MITIGATION

Impacts on the Stone Age

Landscape will be transient, Duration Immediate (1) occurring sporadically and for

limited duration

Understanding of the Stone Age

Landscape of the study area Consequence: Extent Municipal Area (4) will contribute to the scientific Slightly beneficial knowledge of the region (6) Significance: Negligible - positive Stone Age accumulations will (24) Intensity x be preserved through record, type of Very low - positive (1) resulting in a positive change to impact a heritage resource with low significance

It is probable that implementation of proposed mitigation measures will result in a contribution to Probability Probable (4) scientific knowledge and preservation of the archaeological record through documentation

7.4.2 Indirect Impact on Farming Community Sites Stonewalled settlements and material culture remains associated with farming communities were identified on Malokong Hill and within the development footprint respectively. The ceramic scatters and isolated find spots are considered to have been subject to the same geomorphic processes discussed above. These include the following: ■ 7331/FC-011; ■ 7331/FC-014; ■ 7331/FC-035; and ■ 7331/FC-048

These finds within the development footprint were rated with a negligible significance value, and the impact assessment indicates that the Magnetite Project will result in minor negative impact. No further mitigation on these resources is required. It is believed that the identified ceramics are associated with identified stonewalled settlements on Malokong Hill. These include: ■ 7331/FC-002; ■ 7331/FC-003; and ■ 7331/FC-018.

As stated in the HSR, these stonewalled settlements appear to be associated with the Moor Park cluster that is accepted as being of Nguni origin. The site was previously identified by

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Kusel8, where it was noted the largest concentration occurred on the south-western portion of the hill. This was confirmed during the reconnaissance.

Figure 7-1: Stonewalled Settlement on the South-Western Portion of Malokong Hill The stonewalling was first identified along the base of Malokong Hill, where a midden with material culture was recorded. No material culture was collected from the midden and the stratigraphic integrity could not be determined as the necessary permits required under Section 35(4) of the NHRA were not held. The site extends from the base of the hill up along the slopes with the largest concentration occurring in the saddle on the south-western portion (See Figure 7-2).

8 An excavation permit (Permit ID: 453 / Permit No: 80/05/06/008/51) regulated under Section 35(4) of the NHRA was issued to Dr. U. Kusel by SAHRA on 19 July 2005 for the mitigation of the Late Iron Age Settlements on Malokong Hill. The permit is available on SAHRIS (Case ID: 2927) at the following link: http://www.sahra.org.za/sahris/cases/excavations-malokong-hill-mokopane. Beyond the identification of the issued permit, no other information regarding the mitigation of the stonewalled settlement on Malokong Hill was identified during was identified as part of this assessment. A request for a copy of the excavation report to SAHRA was made on 06 January 2015. This was not yet received at the time of compiling this report.

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Figure 7-2: The Approximate Extent of the Stonewalled Settlement indicated in yellow The stonewalled settlements on Malokong Hill have been rated with a high significance. These sites occur outside of the Magnetite Project footprint, but may be indirectly impacted upon during the operational phase of the project. The site is located approximately 700 m from the proposed location of Pit 1. The expected ground vibration at this distance, as per Table 2 in the Blasting and Vibration Impact Assessment is 5.2 PPV. While no accepted standard limitation on vibrations is available for these types of sites, this fall within the parameters of modern structures. For fly-rock, the safe boundary is recommended at no shorter than 500 m. These structures fall outside of this restriction. The potential vibrations and fly-rock from blasting may cause damage to the structures, and threaten the integrity of the sites. This has been rated as a high negative impact. To mitigate the high negative impact identified, it is recommended that the stonewalled settlements be recorded in detail through appropriate archaeological mitigation measures and mapping. This measure will ensure that even if the site is negatively impacted upon, it will be preserved through record and contribute to the understanding of the regional history. Project related activities during the operation of the Magnetite Project will have indirect impacts on farming community stonewalled settlement sites on Malokong Hill. The activities considered are: ■ Development of open pits; and ■ Mine operations.

These activities will have bearing on the heritage aspect. The identified issues and resultant impact will be vibrations and fly rock from blasting that could potentially damage stonewalled structures and threaten the integrity of these sites. It has been demonstrated in the HSR and Literature Review that these stonewalled settlements are associated with the history of the Langa, and therefore arguably their descendent communities. In light of this, indirect impacts

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on the tangible heritage resources may also result in indirect impacts to the intangible heritage resources associated with the sites. The impact assessment for the indirect impact on farming community sites is summarised in Table 7-10. Table 7-10: Summary of Impact Assessment related to Indirect Impacts on Late Farming Community Sites

IMPACT DESCRIPTION: Indirect impacts on farming community sites Predicted for project Operation Decommissioning phase: Dimension Rating Motivation PRE-MITIGATION Damage to the stone walled

structures associated with Late Duration Permanent (7) Farming Communities on Malokong Hill will be permanent

These Farming Community sites are associated with historical events that contribute to national identity and any Consequence: Extent National (6) impact on these will have Extremely implications to tangible and detrimental (-19) Significance: intangible heritage resources Moderate - negative that contribute to national (-95) history The intensity has been rated as Intensity x very high-negative because it is type of Very high - negative (-6) a moderate change to a impact heritage resource with high significance It is likely that blasting and vibrations may negatively impact on the stonewalled structures on Malokong Probability Likely (5) Hill, and any potential intangible social significance associated with the sites MITIGATION:

Adequately record the structure through archaeological mitigation and detailed recording to preserve the site through documentation. The proposed mitigation measures will require a NHRA section 35 Permit issued by SAHRA to a qualified archaeologist.

POST-MITIGATION

The impact to the stonewalled

settlements will extend beyond

Duration Beyond project life (6) the project life, but will be

minimised through mitigation measures Consequence: Significance: Moderately Moderate - positive

The extent of the impact will be beneficial (13) (91)

limited to site specific Extent Limited (2) repercussions, issues or effects while the context will be preserved through record

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Mitigation measures will allow for the detailed recording of the site and context that will contribute to the understanding of the history of the region and Intensity x communities that reside therein. type of High - positive (5) It will also establish the impact intangible heritage components of the sites and allow for the establishment of appropriate management in conjunction with local communities.

It is certain that mitigation measures will positively Probability Certain (7) contribute to the understanding of the history of the region and the communities that reside therein.

7.4.3 Indirect Impact on Indigenous Knowledge Systems In addition to the identified heritage resources, communities issued heritage related comments through the consultation process undertaken as part of the SEP. These comments and responses are detailed under Section 4.1. Magaetsi Manaka requested clarification of the effects of mining on traditional medicinal plants. The Traditional Healers Association also noted that they rely on Mosala-suping for medicinal purposes (See Table 7-11). These plants are harvested from a specific within the development footprint (proposed Plant Area in close proximity to Malokong Hill and FC-002), suggesting that there is some spiritual significance associated with that location. To address this concern, consideration of ethnobotany and the ethnobotanical uses of medicinal plants were required to determine the cultural and historical impacts. Medicinal plants recorded within the project, as presented in the Fauna and Flora Impact Assessment are presented in Table 7-11. Table 7-11: Medicinal Plants Species Recorded within the Magnetite Project

Asparagus sp.

Wild asparagus (English) Katdoring (Afrikaans) Species of this genus are traditionally used in southern Africa for treatment of tuberculosis, kidney ailments and rheumatism. Certain species are part of a remedy for epilepsy.

Dichrostachys cinerea

Sickle bush (English) uGegane, Umthezane (Zulu) Root diffusions and decoctions have been used to treat body pain, backache, elephantiasis, syphilis and leprosy. Also used as a styptic, diuretic, purgative and aphrodisiac. In the Limpopo Province specifically, root decoctions (often mixed with other plants) are used to treat pharyngitis and infertility. Ash from incinerated pods, together with roots of Brackenridgea zanguebarica (often confused with Ochna pulchra which was identified on site), and fruits Solanum aculeatum are mixed with Vaseline to apply to wounds as an ointment.

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Malva parviflora

Mallow (English) Mosala-suping (Ndebele) Leaf infusions are taken orally as a nerve tonic. The Sotho give root decoctions to persons who have lost near relatives. This may be the species reported as Mosala-suping, that is used as a sedative.

Rhoicissus tridentata

Wild Grape (English) Isinwazi (Zulu) Roots and tubers are used to treat stomach ailments, kidney and bladder complaints, infertility and dysmenorrhoea.

Sclerocarya birrea

Marula (English) Morula (Northern Sotho) The bark is used to treat dysentery, diarrhoea and unspecified stomach problems. The bark is also believed to be of value in treating malaria. Chewing the fresh leaves and swallowing the astringent juice is believed to help with indigestion.

Ziziphus mucronata

Buffalo-thorn (English) Mokgalo (Northern Sotho, Tswana) Warm bark infusions (sometimes with roots or leaves added) are used as expectorants (also as emetics) for chest problems. Decoctions of roots and leaves (or chewed leaves) are applied externally to boils, sores and glandular swellings, not only to promote healing but also to relieve pain.

The direct impact on medicinal plants is addressed in the fauna and flora assessment, and recommendations to the mitigation of the identified impacts are presented therein. The cultural historical impacts of those direct impacts are considered here and summarised in Table 7-12. Project related activities during the construction phase, specifically topsoil and vegetation clearing will have direct impacts on the biophysical aspect, and indirect impacts on the heritage aspect through alteration of the perception / experience of medicinal plant users. The identified issues and resultant impacts will be the physical alteration of the lands and removal of traditional medicinal plants that may result in an indirect impact on the perception / experience of the individuals using these resources and Indigenous Knowledge Systems (IKS). The impact assessment for the indirect impact on IKS is summarised in Table 7-12.

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Table 7-12: Summary of Impact Assessment for the Indirect Impact on IKS

IMPACT DESCRIPTION: Indirect impacts on Indigenous Knowledge Systems Predicted for project Pre-construction Construction Operation phase: Dimension Rating Motivation PRE-MITIGATION The removal of medicinal plants Duration Beyond project life (6) will extend beyond the project life, but will reduce over time

The impact will be local in Consequence: Extent Local (3) extent, affecting those residing Moderately around the project area detrimental (-10) Significance: Intensity x The intensity is rated as low, for Minor - negative type of Very low - negative (-1) a heritage resource with (-50) impact negligible significance

It is likely that the removal of medicinal plants will Probability Likely (5) have a negative indirect impact on perception / experience of traditional medicinal plant users.

MITIGATION:

Through consultation with traditional medicinal plant users and the Traditional Healers Association, negotiate and agree to the future management of the traditional plants within the development footprint, possibly including the relocation of the traditional medicinal plants outside of the project area.

POST-MITIGATION If mitigation measures are implemented, the anticipated impact to the perception / Duration Short term (2) experience of traditional medicinal plant users will be limited to the short term

The identified impact will effect Consequence: Extent Very limited (1) communities within a limited Negligible (4) extent Significance: Negligible - positive A positive impact will be (20) Intensity x achieved through type of Very low - positive (1) acknowledgement of impact community IKS, and active support to conserve their IKS It is likely that if mitigation measures are implemented, that perception / experience of Probability Likely (5) traditional medicinal plant users and IKS with regards to the location and use of medicinal plants will not be negatively impacted upon

Here, the removal of topsoil and vegetation during the construction phase will remove traditional medicinal plants that are currently accessible to community members. If this removal of traditional medicinal plants is not mitigated, it may have social implication to communities and results in the gradual erosion of IKS amongst community members. This has been rated as a minor negative impact. It is recommended that communities and traditional healers be consulted to determine the appropriate management of these

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resources. Possible mitigation measures include the relocation of the traditional medicinal plants to an area outside the project footprint. This could potentially result in a minor positive impact where perceptions / experiences are maintained and the facilitation and transmission of IKS is promoted.

8 Cumulative Impacts on the Cultural Landscape Finally, the cumulative impacts of the Magnetite Project must be considered. 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 – implying 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. As demonstrated, the regional and local study area contribute to the Stone Age Landscape and are intimately associated with the history of the Ndebele spanning from the Late Farming Community period through to the present. Historically, the Langa and Kekana chiefdoms were primary players in the events that culminated in the 1854 Siege of Makapan, an event of national significance that has influenced the socio-cultural landscape of the region. These factors indicate that the Magnetite project is situated in a highly sensitive cultural landscape. For the Magnetite Project, cumulative impacts are manifested as additive, synergistic, and space and time crowding cumulative impacts. These are summarised in Table 8-1 and discussed separately below. Table 8-1: Summary of Potential Cumulative Impacts

Direction of Extent of Type Cumulative Impact Change Impact

Additive Local & Space Change to sense-of-place Negative Regional crowding

Additive Increase of informal settlements and urban sprawl that Space may encroach on the archaeological element of the Negative Local crowding cultural landscape

Additive Sterilisation of land of tangible heritage such as Site Specific, Synergistic archaeological sites and consequently possible effect Negative Local & on the integrity of local intangible heritage, e.g. Langa Space Regional crowding and Boer histories, identity, research potential, etc.

Increased significance of remaining in situ Site Specific, Additive archaeological sites and accumulations regardless of Negative Local & Synergistic integrity Regional

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Direction of Extent of Type Cumulative Impact Change Impact Project activities will destroy certain archaeological Synergistic resources, but appropriate mitigation of archaeological Regional & Positive Neutralising sites could contribute to the understanding of the local, National regional and national archaeological record

Activities resulting from Pamish and other

developments will have a cumulative impact on tangible Resource Time heritage resources in and around the development Negative specific & crowding footprint that will remain in situ, e.g. structural integrity site specific of stonewalling on Malokong Hill may be degraded through repetitive blasting

The proposed Magnetite Project in conjunction with other planned and existing developments will have additive and space-crowding cumulative impacts to the local and regional study area. This will entail the sum of all the effects and the high spatial density of impacts on heritage resources resulting in negative cumulative impacts. This may include: ■ Change to sense-of-place from a historic rural landscape to an industrial mining landscape; ■ An increase of informal settlements and urban sprawl that may encroach on the archaeological element of the cultural landscape; and ■ Sterilisation of the land where tangible heritage such as archaeological sites are destroyed and consequently the integrity of the intangible heritage is degraded.

Recognition must also be given to any amendments subsequent to authorisation of the Magnetite Project. This refers to any change to project related activities that require authorisation or redesign of the development footprint that will occur within the site-specific project area. These amendments will contribute to the additive cumulative impact of the Magnetite Project. Synergistic cumulative impacts were also identified. These impacts are categorised as the interaction of individual effects to produce a total effect greater than the sum of the individual effect. Both negative and positive synergistic cumulative impacts by the Magnetite Project were identified. These included: ■ Increased cultural significance of remaining in situ archaeological sites and accumulations regardless of integrity; and ■ Where archaeological resources are to be destroyed by project activities, the appropriate mitigation of archaeological sites could contribute to the understanding of the local, regional and national archaeological record.

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The potential contribution of mitigations to the understanding of the local, regional and national archaeological record will also have a neutralising cumulative impact. This is defined as where the effect of appropriate mitigation may counteract the destruction of archaeological resources to reduce the overall effect of the proposed Magnetite Project on the archaeological element of the cultural landscape. Finally, time-crowding negative cumulative impact was also identified. This is understood as the frequent, repetitive impacts on a particular resource at the same time. In the case of the Magnetite Project, in combination with other established operation in the local and site specific study area, late farming community sites on Malokong Hill may be structurally compromised through repetitive blasting activities. These were also considered under Section 7.4.2.

9 Unplanned Events and Low Risks Certain project activities may represent low risks or cause unplanned events. Low risks can be monitored to gauge if the baseline changes and mitigation is required. Unplanned events may happen on any project. Information on potential impacts of those events and management plans are provided in this section. Table 9-1 summarises possible low risks and unplanned events that could potential impact on certain heritage resources. Table 9-1: Unplanned Events, Low Risks and their Management Measures

Unplanned event Potential impact Mitigation/ Management/ Monitoring Blast effects on karst Prior to construction the conservation status of the karst topography topography must be determined; this may be done by

the mine . Breakage of If conservation status is sound, a palaeontologist and / stalagmites and or archaeologist should undertake a survey to Dewatering of karts stalactites and roof determine the potential of hominin and other caves cracks or collapse. archaeological remains. In the event that any significant finds are made, a monitoring process will need to be developed to ensure the sustainable conservation of the cave system.

Blast effects on Damage to grave Project specific CFPs must be developed that provide burial grounds dressings. reporting structures and management measures in the surrounding Restricted access event of discovery or accidental exposure of previously development to visitors during unknown graves. footprint area. blasting periods. Where previously unidentified burial grounds and

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Unplanned event Potential impact Mitigation/ Management/ Monitoring graves are identified in the development footprint, a Burial Grounds and Consultation Process (BGGC) as regulated by Section 36 of the NHRA and Chapter XI of

Destruction of the Regulations to the Act must be implemented to: Accidental exposure graves and 1. Identify as far as possible bona fide Next-of-Kin of graves / human possible contents (NoK) remains of graves. 2. Consult and reach agreement with NoK as to the appropriate management of the burial ground or grave either through a Conservation Management Plan (CMP) or if required, Grave Relocation Plan (GRP).

9.1 Low Risk to Karst Landscape As demonstrated in the HSR, the palaeontological significance of the development footprint is insignificant. There are no surface exposures of Malmani dolomites within the project area. The Malmani subgroup stratigraphically underlies the project area; however the relationship of the project to the underlying dolomites is unclear in terms of depth or structural interconnectivity (fractures). The Makapan Valley is located approximately 40 km south-east of the project area and is of considerable archaeological importance, however the distance from the project site will resulting in a negligible to low risk. Presently, the significance and integrity of karst topography demonstrates that there is high scientific information potential (Table 9-2). Table 9-2: Cultural Significance Rating for the Karst Topography within the Study Area

Resource ID Type Description Significance CS Motivation

On the scientific

aspect, Karst Karst topography Karst Topography Natural feature High geology is rare and within the study area uncommon and of high importance

An unplanned potential future risk / event may be attributed to groundwater contamination reaching the dolomites affecting the quality of the aquifer or increasing the potential for dissolution. Further investigation is required on the relationship of the project to the Malmani dolomites before this risk can be quantified / qualified. Blast induced vibrations and shockwaves can cause stalagmites and stalactites to break and may cause cave roofs to crack or collapse. A review of the Blasting and Vibration Impact Assessment for the Magnetite Project indicated that the expected levels of ground vibrations for various charges decrease significantly over distance. At 2.5 km from the closest point to

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the development footprint, the expected ground vibrations at the maximum discharge have been calculated to 0.6 Peak Particle Velocity (PPV). While no accepted limits of ground vibrations for karst topography is prescribed, a value of 0.6 PPV is well below the limits for structures and human perception. However, further investigation is required on the relationship of the project to the Malmani dolomites before this risk can be quantified / qualified.

Magnetite Mine Project

Expected Levels of Ground Vibration for Various Charges @ Specific Distances

Min Charge / Delay Max. Charge / Delay Bottom Limit (mm/s) Mid. Limit (mm/s) Top Limit (mm/s)

140

120

100 (mm/s)

80 Vibration

Ground 60

40 Predicted

20

0 0 500 1000 1500 2000 2500

Distance (m)

Figure 9-1: Ground Vibration Over Distance for the Two Charge Masses used in Modelling

9.2 Low Risks to Burial Grounds and Graves General concern was raised in relation to the treatment of graves. All identified burial grounds and graves are situated outside of the development footprint of the Magnetite Project, with the closest cemetery, BGG-001 situated more than 600 m away. This is well outside the prescribed distance for fly-rock. No graves were identified within the development footprint. This finding was re-iterated by community members who on separate occasions stated that no graves are known to occur within the development footprint. Having stated this, it is recommended that appropriate Chance Finds Protocols (CFPs) are developed to manage the accidental discovery of unknown graves during the construction and operational phases of the Magnetite Project.

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10 Conclusion Pamish are proposing to develop the Magnetite Project some 35 km northwest of Mokopane town, within Limpopo Province. Digby Wells compiled an NID and HSR as part of the specialist heritage study. This report constitutes the HIA submitted to SAHRA and LIHRA for Statutory Comment as required under Section 38(8) of the NHRA. Reconnaissance of the development footprint was completed in March 2015. A total of 47 tangible heritage resources were identified (See Table 7-4). These sites were designated with significance ratings ranging from negligible to high. In relation to the impacts identified and discussed under Section 7 the following recommendations apply: ■ Identified heritage resources with negligible significance have been sufficiently recorded and no further mitigation is required on these individual accumulations; ■ Stone Age accumulations suggest that there is a potential for subsurface deposit that could contribute to the understanding of the Stone Age Landscape of the study area, specifically MSA habitation. It is recommended that augering or STPs of the development footprint be undertaken prior to pre-construction activities with the necessary permits regulated under Section 35 of the NHRA to contribute to the knowledge of the MSA habitation of the area. This must be undertaken by a qualified archaeologist; ■ To address the indirect impact on farming community stonewalled sites and the additive cumulative impact on the cultural landscape, record identified sites on Malokong Hill in detail through archaeological mitigation and detailed mapping prior to pre-construction activities with the necessary permits regulated under Section 35 of the NHRA. This must be undertaken by a qualified archaeologist; ■ The Traditional Healers Association and surrounding communities must be consulted with in regards to traditional medicinal plants. Consultation should endeavour to reach agreement between Pamish and the community as to the management and mitigation of traditional medicinal plants within the development footprint; and ■ CFPs must be developed and included as a condition of authorisation that outline reporting structures and management processes for the accidental discovery or exposure of unknown heritage resources during construction and operational phases of the Magnetite Project. Where previously unidentified burial grounds and graves are identified in the development footprint, a Burial Grounds and Consultation Process (BGGC) as regulated by Section 36 of the NHRA and Chapter XI of the Regulations to the Act must be implemented to: . Identify as far as possible bona fide Next-of-Kin (NoK); and

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. Consult and reach agreement with NoK as to the appropriate management of the burial ground or grave either through a Conservation Management Plan (CMP) or if required, Grave Relocation Plan (GRP).

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Appendix A: Declaration of Independence

Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Digby Wells and Associates (South Africa) (Pty) Ltd

Contact person: Justin du Piesanie Turnberry Office Park Tel: 011 789 9495 48 Grosvenor Road Fax: 011 789 9498 Bryanston E-mail: [email protected]

2191 South Africa

I, Justin du Piesanie as duly authorised representative of Digby Wells and Associates (Pty) Ltd., hereby confirm my independence (as well as that of Digby Wells and Associates (Pty) Ltd.) and declare that neither I nor Digby Wells and Associates (Pty) Ltd. have any interest, be it business, financial, personal or other, in any proposed activity, application or appeal in respect of VM Investment Company or Pamish Investment No. 39 (Pty) Ltd, other than fair remuneration for work performed, specifically in connection with the Heritage Resources Management (HRM) Process for the proposed Magnetite Project, Limpopo Province.

Full name: Justin du Piesanie Title/ Position: Heritage Management Consultant: Archaeologist Qualification(s): MSc in Archaeology Experience (years): 6 years

Registration: Association of Southern African Professional Archaeologists (ASAPA) International Council on Monuments and Sites (ICOMOS) South Africa

Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

University of the Witwatersrand

Contact person: Tammy Hodgskiss Evolutionary Studies Institute Tel: 083 688 3478 University of the Witwatersrand Fax: - 1 Jan Smuts Avenue E-mail: [email protected]

2050

I, Tammy Hodgskiss as duly authorised representative of Digby Wells and Associates (Pty) Ltd., hereby confirm my independence (as well as that of Digby Wells and Associates (Pty) Ltd.) and declare that neither I nor Digby Wells and Associates (Pty) Ltd. have any interest, be it business, financial, personal or other, in any proposed activity, application or appeal in respect of VM Investment Company or Pamish Investment No. 39 (Pty) Ltd, other than fair remuneration for work performed, specifically in connection with the Heritage Resources Management (HRM) Process for the proposed Magnetite Project, Limpopo Province.

Full name: Tammy Hodgskiss Title/ Position: Specialist Sub-contractor: Stone Age Archaeologist Qualification(s): PhD in Archaeology Experience (years): 8 years Registration: Association of Southern African Professional Archaeologists (ASAPA)

Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Appendix B: Specialists CV

Mr. Justin du Piesanie Heritage Management Consultant: Archaeologist Social Sciences Department Digby Wells Environmental

1 Education

Date Degree(s) or Diploma(s) obtained Institution

2013 Continued Professional Development University of Cape Town Programme, 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

3 Employment

Period Company Title/position

08/2011 to Digby Wells Environmental Heritage Management present Consultant: Archaeologist

______Digby Wells and Associates (South Africa) (Pty) Ltd (Subsidiary of Digby Wells & Associates (Pty) Ltd). Co. Reg. No. 2010/008577/07. Fern Isle, Section 10, 359 Pretoria Ave Randburg Private Bag X10046, Randburg, 2125, South Africa Tel: +27 11 789 9495, Fax: +27 11 789 9498, [email protected], www.digbywells.com

______Directors: A Sing*, AR Wilke, DJ Otto, GB Beringer, LF Koeslag, AJ Reynolds (Chairman) (British)*, J Leaver*, GE Trusler (C.E.O) *Non-Executive ______

p:\company_info\staff_cvs_and_bios\cvs\7_heritage\j_du_piesanie_2014.docx

Period Company Title/position

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 Professional Affiliations

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

5 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

6 Experience I have 5 years experiences in the field of heritage resources management (HRM) including archaeological and heritage assessments, grave relocation, social consultation and mitigation of archaeological sites. During my studies I was involved in academic research projects associated with the Stone Age, Iron Age, and Rock Art. These are summarised below: ■ Wits Fieldschool - Excavation at Meyersdal, Klipriviersberg Johannesburg (Late Iron Age Settlement). ■ Wits Fieldschool - Phase 1 Survey of Prentjiesberg in Ugie / Maclear area, Eastern Cape. ■ Wits Fieldschool – Excavation at Kudu Kopje, Mapungubwe National Park Limpopo Province.

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■ Wits Fieldschool – Excavation of Weipe 508 (2229 AB 508) on farm Weipe, Limpopo Province. ■ Survey at Meyerdal, Klipriviersberg Johannesburg. ■ Mapping of Rock Art Engravings at Klipbak 1 & 2, Kalahari. ■ Survey at Sonop Mines, Windsorton Northern Cape (Vaal Archaeological Research Unit). ■ Excavation of Kudu Kopje, Mapungubwe National Park Limpopo Province. ■ Excavation of KK (2229 AD 110), VK (2229 AD 109), VK2 (2229 AD 108) & Weipe 508 (2229 AB 508) (Origins of Mapungubwe Project) ■ Phase 1 Survey of farms Venetia, Hamilton, Den Staat and Little Muck, Limpopo Province (Origins of Mapungubwe Project) ■ Excavation of Canteen Kopje Stone Age site, Barkley West, Northern Cape ■ Excavation of Khami Period site AB32 (2229 AB 32), Den Staat Farm, Limpopo Province Since 2011 I have been actively involved in environmental management throughout Africa, focusing on heritage assessments incompliance with International Finance Corporation (IFC) Performance Standards and other World Bank Standards and Equator Principles. This exposure to environmental, and specifically heritage management has allowed me to work to international best practice standards in accordance with international conservation bodies such as UNESCO and ICOMOS. In addition, I have also been involved in the collection of quantitative data for a Relocation Action Plan (RAP) in Burkina Faso. The exposure to this aspect of environmental management has afforded me the opportunity to understand the significance of integration of various studies in the assessment of heritage resources and recommendations for feasible mitigation measures. I have work throughout South Africa, as well as Burkina Faso, the Democratic Republic of Congo, Liberia and Mali.

7 Project Experience Please see the following table for relevant project experience:

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Project Title Project Date: Description of the Project Role of Firm Own Role in Time Name of Contract Reference Location in the Project the Project involved Client Outcomes (man months) Klipriviersberg Meyersdal, 2005 2006 Survey of residential Archaeological Researcher, 2 months Completed survey, Archaeological Resource Management Archaeological Gauteng, South development in Meyersdal. Impact Archaeological excavations and (ARM) Survey Africa This included the recording Assessments Assistant reporting Prof T.N. Huffman of identified stone walled [email protected] settlements through detailed mapping and photographs. Included was the Phase 2 Mitigation of two stone walled settlements Sun City Sun City, 2006 2006 Recording of an identified Mapping Archaeological 1 month Sun City Completed Archaeological Resources Archaeological Site Pilanesberg, Late Iron Age stonewalled Assistant, mapping Management (ARM) Mapping North West settlement through detailed Mapper Prof T.N. Huffman Province, South mapping [email protected] Africa Witbank Dam Witbank, 2007 2007 Archaeological survey for Archaeological Archaeological 1 week Completed Archaeological Resources Archaeological Mpumalanga, proposed residential Impact Assistant Archaeological Management (ARM) Impact South Africa development at the Witbank Assessment Impact Assessment Prof T.N. Huffman Assessment dam report [email protected] Archaeological Johannesburg, 2008 2008 Archaeological survey and Archaeological Archaeologist 1 month Completed the Heritage Contracts Unit Assessment of Gauteng, South basic assessment of Impact assessment of 13 Jaco van der Walt Modderfontein AH Africa Modderfontein Holdings Assessment properties [email protected] Holdings Heritage Thabazimbi, 2008 2008 Heritage Assessment for Heritage Archaeologist 2 weeks Rhino Mines Completed the Archaeological Resources Assessment of Limpopo expansion of mining area at Impact assessment Management (ARM) Rhino Mines Province, South Rhino Mines Assessment Prof T.N. Huffman Africa [email protected] Cronimet Project Thabazimbi, 2008 2008 Archaeological survey of Archaeological Archaeologist 1 weeks Cronimet Completed field Heritage Contracts Unit Limpopo Moddergat 389 KQ, Impact survey and Jaco van der Walt Province, South Schilpadnest 385 KQ, and Assessment reporting [email protected] Africa Swartkop 369 KQ,

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Eskom Limpopo 2008 2008 Heritage Statement defining Heritage Archaeologist 2 months Eskom Completed Heritage Heritage Contracts Unit Thohoyandou SEA Province, South the cultural landscape of Statement Statement Jaco van der Walt Project Africa the Limpopo Province to [email protected] assist in establishing sensitive receptors for the Eskom Thohoyadou SEA Project Wenzelrust Shoshanguve, 2009 2009 Contracted by the Heritage Excavation and Archaeologist 1 week Heritage Completed Heritage Contracts Unit Excavations Gauteng, South Contracts Unit to help Mapping Contracts Unit excavations Jaco van der Walt Africa facilitate the Phase 2 [email protected] excavations of a Late Iron Age / historical site identified in Shoshanguve University of the Parys, Free 2009 2009 Mapping of a Late Iron Age Mapping Archaeologist 1 day University of Completed University of the Witwatersrand Witwatersrand State, South rock shelter being studied the mapping of the Karim Sadr Parys LIA Shelter Africa by the Archaeology Witwatersrand shelter [email protected] Project Department of the University of the Witwatersrand Transnet NMPP Kwa-Zulu Natal, 2010 2010 Heritage Survey of the Heritage Archaeologist 1 week Umlando Completed survey Umlando Consultants Line South Africa Anglo-Boer War Vaalkrans Impact Consultants Gavin Anderson Battlefield where the Assessment [email protected] servitude of the NMP pipeline Archaeological Johannesburg, 2010 2010 Heritage survey of Archaeological Archaeologist 1 week ARM Completed survey Archaeological Resources Impact Gauteng, South Witpoortjie 254 IQ, Impact for the AIA Management (ARM) Assessment – Africa Mindale Ext 7 and Assessment Prof T.N. Huffman Witpoortjie Project Nooitgedacht 534 IQ for [email protected] residential development project Der Brochen Steelpoort, 2010 2010 Phase 2 archaeological Archaeological Archaeologist 2 weeks Heritage Completed Heritage Contracts Unit Archaeological Mpumalanga, excavations of Late Iron Excavation Contracts Unit excavations Jaco van der Walt Excavations South Africa Age Site [email protected] De Brochen and Steelpoort, 2010 2010 Mapping of archaeological Mapping Archaeologist 1 week Heritage Completed Heritage Contracts Unit Booysendal Mpumalanga, sites 23, 26, 27, 28a & b on Contracts Unit Mapping Jaco van der Walt Archaeology South Africa the Anglo Platinum Mines [email protected] Project De Brochen and Booysendal

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Eskom Limpopo 2010 2010 Desktop study to identify Desktop Study Archaeologist 1 Month Strategic Completed Report Strategic Environmental Focus (SEF) Thohoyandou Province, South heritage sensitivity of the Environmental Vici Napier Electricity Master Africa Limpopo Province Focus [email protected] Network Batlhako Mine North-West 2010 2010 Mapping of historical sites Mapping Archaeologist 1 week Heritage Completed Heritage Contracts Unit Expansion Province, South located within the Batlhako Contracts Unit Mapping Jaco van der Walt Africa Mine Expansion Area [email protected] Kibali Gold Project Orientale 2011 2013 Implementation of the Grave Archaeologist 2 years Randgold Successful Kibali Gold Mine Grave Relocation Province, Grave Relocation Project Relocation Resources relocation of Cyrille Mutombo Plan Democratic for the Randgold Kibali approximately 3000 [email protected] Republic of Gold Project graves Congo Kibali Gold Hydro- Orientale 2012 2014 Assessment of 7 proposed Heritage Heritage 2 years Randgold Completed Heritage Randgold Resources Power Project Province, hydro-power stations along Impact Consultant Resources Impact Assessment Charles Wells Democratic the Kibali River Assessment [email protected] Republic of Congo Everest North Steelpoort, 2012 2012 Heritage Impact Heritage Heritage 6 months Aquarius Completed Heritage Aquarius Resources Mining Project Mpumalanga, Assessment on the farm Impact Consultant Resources Impact Assessment South Africa Vygenhoek Assessment Environmental Gauteng, South 2012 2012 Heritage impact Heritage Heritage 4 months Gold One Completed Heritage Gold One International Authorisation for Africa Assessment for the Impact Consultant International Impact Assessment the Gold One proposed TSF and Pipeline Assessment Geluksdal TSF and of Geluksdal Mine Pipeline Platreef Burial Mokopane, 2012 2012 Survey for Burial Grounds Burial Grounds Heritage 4 months Platreef Project closed by Platreef Resources Grounds and Limpopo and Graves and Graves Consultant Resources client due to safety Gerick Mouton Graves Survey Province, South Management risks Africa Plan Resgen Limpopo 2012 2012 Archaeological Excavation Archaeological Heritage 4 months Resources Completed Resources Generation Boikarabelo Coal Province, South of identified sites Excavation Consultant Generation excavation and Louise Nicolai Mine Africa reporting, destruction permits approved Bokoni Platinum Burgersfort, 2012 2012 Watching brief for Watching Brief Heritage 1 week Bokoni Completed Bokoni Platinum Mines (Pty) Ltd Road Watching Limpopo construction of new road Consultant Platinum Mine watching brief, Brief Province, South reviewed report Africa

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SEGA Gold Mining Burkina Faso 2012 2013 Socio Economic and Asset RAP Social 3 months Cluff Gold Completed field Cluff Gold PLC Project Survey Consultant PLC survey and data collection SEGA Gold Mining Burkina Faso 2013 2013 Specialist Review of Reviewer Heritage 1 week Cluff Gold Reviewed specialist Cluff Gold PLC Project Heritage Impact Consultant PLC report and made Assessment appropriate recommendations Consbrey and Breyton, 2013 2013 Heritage Impact Heritage Heritage 2 months Msobo Completed Heritage Msobo Harwar Collieries Mpumalanga, Assessment for the Impact Consultant Impact Project South Africa proposed Consbrey and Assessment Assessments Harwar Collieries New Liberty Gold Liberia 2013 2014 Implementation of the Grave Heritage On-going Aureus Mining Project is on-going Aureus Mining Project Grave Relocation Project Relocation Consultant for the New Liberty Gold Project Falea Uranium Falea, Mali 2013 2013 Heritage Scoping for the Heritage Heritage 2 months Rockgate Completed scoping Rockgate Capital Mine proposed Falea Uranium Scoping Consultant Capital report and Environmental Mine recommended Assessment further studies Putu Iron Ore Mine Petroken, 2013 2014 Heritage impact Heritage Heritage 6 months Atkins Limited Completed Heritage Atkins Limited Project Liberia Assessment for the Impact Consultant Impact Assessment Irene Bopp proposed Putu Iron Ore Assessment and provided [email protected] Mine, road extension and recommendations railway line for further studies Sasol Twistdraai Secunda, 2013 2014 Notification of intent to NID Heritage 2 months ERM Southern Completed NID and ERM Southern Africa Project Mpumalanga, Develop and Heritage Consultant Africa Heritage Statement Alan Cochran South Africa Statement for the Sasol [email protected] Twistdraai Expansion Daleside Acetylene Gauteng, South 2013 2013 Project Management of the NID Project 3 months ERM Southern Project completed ERM Southern Africa Gas Production Africa heritage study Manager Africa Kasantha Moodley Facility [email protected] Exxaro Belfast, Belfast, 2013 2014 Grave Relocation Plan for GRP Project On-going Exxaro Project is on-going Exxaro Paardeplaats and Mpumalanga, the Belfast, Paardeplaats Manager, Johan van der Bijl Eerstelingsfontein South Africa and Eerstelingsfontein Heritage [email protected] GRP Projects Consultant

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Nzoro 2 Hydro Orientale 2014 2014 Social consultation for the RAP Social On-going Randgold Completed Kibali Gold Mine Power Project Province, Relocation Action Plan Consultant Resources introductory Cyrille Mutombo Democratic component of the Nzoro 2 meetings – project [email protected] Republic of Hydro Power Station on-going Congo Eastern Basin Springs, 2014 2014 Heritage Impact Heritage Heritage On-going AECOM Project is on-going AECOM AMD Project Gauteng, South Assessment for the Impact Consultant Africa proposed new sludge Assessment storage facility and pipeline Soweto Cluster Soweto, 2014 2014 Heritage Impact Heritage Heritage On-going ERGO Project is on-going ERGO Reclamation Gauteng, South Assessment for reclamation Impact Consultant Greg Ovens Project Africa activities associated with Assessment [email protected] the Soweto Cluster Dumps Klipspruit South Ogies, 2014 2014 NID and Heritage NID Heritage On-going BHP Billiton Project is on-going BHP Billiton Project Mpumalanga, Statement for the Section Consultant South Africa 102 Amendment of the Klipspruit Mine EMP Klipspruit Ogies, 2014 2014 NID and Heritage NID Heritage On-going BHP Billiton Project is on-going BHP Billiton Extension: Mpumalanga, Statement for the Consultant Weltevreden South Africa expansion of the Klipspruit Project Mine Ergo Rondebult Johannesburg, 2014 2014 NID and Heritage NID Heritage 1 Week ERGO Completed ERGO Pipeline Basic South Africa Statement for the Consultant screening Assessment construction of the assessment and Rondebult Pipeline NID Kibali ESIA Update Orientale 2014 2014 Update of the Kibali ESIA Heritage Heritage On-going Randgold Project is on-going Randgold Resources Project Province, for the inclusion of new Impact Consultant Resources Charles Wells Democratic open-cast pit areas Assessment [email protected] Republic of Congo GoldOne EMP Westonaria, 2014 2014 Gap analysis for the EMP Gap Analysis Heritage On-going Gold One Project is on-going Gold One International Consolidation Gauteng, South consolidation of operations Consultant International Africa west of Johannesburg

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Curriculum Vitae

Tamaryn Penny Reynard (née Hodgskiss), Ph.D.

Personal Particulars

Surname Reynard First name Tamaryn (Tammy) Identity number 8104270129085 Date of birth 27 April 1981 Gender Female Marital status Married (née Hodgskiss) Nationality South African Place of birth Johannesburg Home language English Other language Afrikaans Driver’s license Code B Tax Number 1125074151 Home and Postal address 18a 4th Avenue Westdene 2092 Johannesburg Phone +27(0)83.688.3478

Education

2013. Doctor of Philosophy (by publication). Middle Stone Age Archaeology. University of the Witwatersrand

2006. Master of Science, with distinction. Middle Stone Age Archaeology. University of the Witwatersrand

2004. Bachelor of Arts with Honours, in Later Stone Age Archaeology. University of the Witwatersrand

2003. Bachelor of Arts in Archaeology and English. University of the Witwatersrand

1998. National Senior Certificate. Greenside High School. Subjects: English, Afrikaans, Mathematics, History, isiZulu and Biology.

Employment History

March 2015 – ongoing. Post-doctoral Research Fellow, Evolutionary Studies Institute, University of the Witwatersrand.

April 2013 – October 2014. Roger Layton Associates (The ETHER Initiative). Head of ETHER Education and Digitisation Business units.

April 2007 – January 2009. South African Rock Art Digital Archive (SARADA). Primary Digitising Officer.

June 2006 – November 2006 Sterkfontein Caves (Maropeng). Tour guide at the Sterkfontein Caves in the Cradle of Humankind.

Archaeological fieldwork and practical experience

 2013. Researcher and co-writer of course content and notes on the (pre-)history of water use, for Prof. Johann Tempelhoff, North West University.  1999 – 2012. Participated in numerous excavations and surveys at Doctorate, Masters, Honours and undergraduate levels, at Later, Middle, Early Stone Age and Iron Age sites in Limpopo, Northern Province and KwaZulu-Natal, South Africa.  2004 – 2012. Participated in seven excavation seasons excavating the Middle Stone Age layers at Sibudu, KwaZulu-Natal. Under the directorship of Prof. Lyn Wadley.  2003. Completed a Heritage Management course at Honours level (in the Makgabeng, Limpopo) with Prof. Benjamin Smith.  2001 – 2003. Performed rock art studies in the Waterberg and Makgabeng.  2000 – 2003. Site surveying and salvage work at Honours and undergraduate levels in Limpopo.

Laboratory, data capture and tutoring experience

 2009 – 2014. Part time data capturing and laboratory work for Prof. Lyn Wadley.  2004. Tutor of first year students Palaeontology and Evolution course, the University of the Witwatersrand.  2004 – 2005. Part time data capturing of Middle Stone Age stone tool assemblages for Dr Paola Villa.  2002 – 2006. Part time laboratory work in the Archaeology Department on Middle Stone Age and Later Stone Age stone tool assemblages, for Prof. Lyn Wadley and Prof. Karim Sadr respectively.

 2003. Assistant to Prof. Karim Sadr during excavations in the Klipriviersberg, Gauteng.

Publications

 Wadley, L., Hodgskiss, T.P., Grant, M. 2009. Implications for complex cognition from the hafting of tools with compound adhesives in the Middle Stone Age, South Africa. Proceedings of the National Academy of Science, USA, 106(24): 9590–9594.  Hodgskiss, T. 2010. Identifying grinding, scoring and rubbing use-wear on experimental ochre pieces. Journal of Archaeological Science 37(12): 3344–3358.  Hodgskiss, T. 2012. An investigation into the properties of the ochre from Sibudu, KwaZulu-Natal, South Africa. Southern African Humanities 24, 99–120.  Hodgskiss, T. 2013. Ochre use in the Middle Stone Age at Sibudu: grinding, rubbing, scoring and engraving. Journal of African Archaeology 11(1): 75–95.  Hodgskiss, T. 2014. The cognitive requirements for ochre use in the Middle Stone Age at Sibudu, South Africa. Cambridge Archaeological Journal 24(3): 405–428.

Presentations

 2013 – 2014. ETHER 2-day Workshops on the Digitisation of Heritage Collections.  2012. “Ochre use at Sibudu Cave and its link to complex cognition in the Middle Stone Age”. Preliminary PhD results presented at the Society of Africanist Archaeologists (SAfA) Conference in Toronto, Canada.  2010. “Identifying grinding, scoring and rubbing use-wear on experimental ochre pieces”. PhD experimental results presented at the Pan African/Safa (Society for Africanist Archaeologists) Congress in Dakar, Senegal.  2011. Poster presented at the ASAPA (Association for South African Professional Archaeologists) Conference in Swaziland.  2006. “Gender in Archaeology”. Public Lecture given at Maropeng.  2006. “In the mix: Replication studies to test the effectiveness of ochre in adhesives for tool hafting”. Masters Dissertation presented by poster at The African Genesis Conference: a symposium on hominid evolution in Africa.  2005. Preliminary Masters Dissertation finds presented at the Pan African Archaeological Congress in Botswana.  2004. Honours research presented by poster and intended masters research presented at the Southern African Association of Archaeologists’ Conference, in Kimberley.

Academic grants, scholarships and bursaries

 Centre of Excellence in Palaeosciences (CoE_Pal) grant for Post-doctoral research in 2015.

 Innovation Scholarship from the National Research Foundation (NRF) received in 2010 – 2012.  Recipient of a SAfA Travel Grant for the Society for Africanist Archaeologists’ (SAfA) conference in Toronto, Canada, 2012.  Wenner-Gren funding received for the PanAf Conference in Dakar, Senegal, 2010.  National Research Foundation (NRF) bursaries received in 2003, 2004 and 2005.  Palaeoanthropological Scientific Trust (PAST) bursaries received in 2004, 2005, 2009-2011.

Academic Awards

 2010 – 2012. Mellon Mentoring Programme Award.  2003 – 2004. Post Graduate Merit Award.

Computer and Microscopy Skills

 MS Word, MS Excel, PowerPoint, Mac, internet and email.  Working knowledge of GIMP and Photoshop (image manipulation) and SPSS (statistics).  Good knowledge of how to use a microscope and microscope camera.  Working knowledge of how to perform Scanning Electron Microscope–Energy Dispersive X-ray Spectroscopy (SEM–EDS) and how to use a handheld X-Ray Fluorescence (XRF) Spectrometer.  Working knowledge of SAHRIS.

Skills and qualities

 Excellent and thorough researcher  Good writing and editing skills  Good communication and inter-personal skills  Able to work well independently and on a team  Passion for culture, prehistory and history (and its preservation)  Analytical and critical thinker  Able to work well under pressure

Membership of professional organisations

 Association for South African Professional Archaeologists (ASAPA). Member since 2004.  Society of Africanist Archaeologists (SAfA). Member since 2010.  The South African Archaeological Society (Arch Soc). Member since 2004.

References

1. Mr Roger Layton Chief Executive Officer at Roger Layton Associates [email protected] 2. Professor Lyn Wadley Professor Emeritus, University of the Witwatersrand [email protected] 3. Mr Azizo da Fonseca Director of the Ringing Rocks Digital Laboratory (South African Rock Art Digital Archive) [email protected]

Heritage Impact Assessment Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Appendix C: Stone Age Report

Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province

Stone Age Report

Project Number:

VMC3049

Prepared for: Pamish Investments No. 39 (Pty) Ltd

July 2015

______Digby Wells and Associates (South Africa) (Pty) Ltd (Subsidiary of Digby Wells & Associates (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 11 789 9498, [email protected], www.digbywells.com ______Directors: DJ Otto, GB Beringer, LF Koeslag, AJ Reynolds (Chairman) (British)*, J Leaver*, GE Trusler (C.E.O) *Non-Executive ______

This document has been prepared by Digby Wells Environmental.

Report Type: Stone Age Report

Proposed Open Pit Magnetite Mine and Concentrator Plant, Project Name: Mokopane, Limpopo Province

Project Code: VMC3049

Name Responsibility Signature Date

Reconnaissance Tammy Hodgskiss and Report April 2015 ASAPA Member 258 Compilation

Justin du Piesanie Review April 2015 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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Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

EXECUTIVE SUMMARY

Pamish Investments No. 39 (Pty) Ltd (Pamish) are proposing to develop a new opencast Magnetite mine approximately 35 kilometres (km) northwest of Mokopane town, within Limpopo Province (i.e. the Magnetite Project). Digby Wells Environmental (Digby Wells) was appointed to undertake the environmental and social baseline studies required for the MRA and EA, according to national legislative requirements and international best practices standards and principles. This document presents the specialist Stone Age report to inform the greater project report and impact assessment. Many Middle Stone Age stone tool scatters were located and identified during the survey. The stone tools in the project area are mostly made form fine-grained felsic tuff. The tools are mostly informal and rarely have formal retouch. Fluvial and colluvial activities in the project area have affected the archaeological record by displacing tools and sediment around the landscape. No habitation or factory sites were found and none of the artefacts are found within their primary context.

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Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

TABLE OF CONTENTS

1 Introduction ...... 1

2 Project Description ...... 1

2.1 Terms of Reference ...... 1 2.2 Scope of Work ...... 2 2.3 Project Limitations ...... 2 3 Methodology ...... 3

3.1 Qualitative Data Collection ...... 3 3.2 Field Based Data Collection ...... 3 3.2.1 Stone Age Survey Methodology ...... 4 4 Regional Stone Age Landscape Description ...... 5

4.1 Geological Landscape ...... 5 4.2 Fluvial Processes ...... 5 4.3 Soils and Sediments ...... 6 4.4 The Stone Age ...... 8 4.4.1 Hominin evolution and the Early Stone Age ...... 8 4.4.2 Middle Stone Age ...... 9 4.4.3 Later Stone Age ...... 9 5 Findings and Discussion...... 10

6 Statement of Significance ...... 12

7 Conclusions and Specialist Recommendations ...... 13

8 References ...... 14

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Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

LIST OF FIGURES

Figure 4-1: Eroded Calcrete, Fluvial Channel at the Base of Malokong Hill, outside of the Magnetite Project Impact Footprint Area ...... 7 Figure 4-2: Cracked Vertic Soils found in the Magnetite Project Impact Footprint Area 7 Figure 4-3: Bright Red Soil containing (unutilised) Quartz and Magnetite Nodules found in some areas of the Magnetite Project Impact Footprint Area ...... 8 Figure 5-1: Examples of some of the MSA Tools found in Magnetite Project Impact Footprint Area, all made from Felsic Tuff. a) Unifacial Point, b) Hammerstone, c) Radial Core, d) Irregular Flakes ...... 11

LIST OF APPENDICES

Appendix A: Declaration of Independence Appendix B: Plans

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Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

1 Introduction Pamish Investments No. 39 (Pty) Ltd (Pamish) are proposing to develop a new opencast Magnetite mine approximately 35 kilometres (km) northwest of Mokopane town, within Limpopo Province (i.e. the Magnetite Project). The applicant is bound by national legislation to submit a Mining Right Application (MRA) to the Department of Mineral Resources (DMR), and simultaneously apply for Environmental Authorisation (EA) from the Department of Environmental Affairs (DEA). This document reports on the Stone Age artefacts and assemblages found in the proposed impact footprint area of the Magnetite Project to inform the Heritage Impact Assessment (HIA), required in terms of section 38(8) of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA).

2 Project Description The proposed Magnetite Project is a greenfields operation situated approximately 33 km north-west of Mokopane, within a rural setting. The prospecting right area comprises several farms, namely Vogelstruisfontein 765 LR, Vriesland 781 LR, Vleigekraal 783 LR, Schoonoord 786 LR and portions Re/1, Re/2, 3, 4, 5 and 6 of the farm Bellevue 808 LR. Probable project- affected villages include Ditlotswana, Malokong, Mosate and Sepharane. Digby Wells compiled a Notification of Intent to Develop (NID) and draft Heritage Scoping Report (HSR) as part of the specialist heritage study. The NID and draft HSR were submitted to the South African Heritage Resources Agency (SAHRA) and Limpopo Heritage Resources Authority (LIHRA) via the South African Heritage Resources Information System (SAHRIS) (Case ID: 7331) on 12 March 2015 for Statutory Comment as prescribed under section 38(8) of the NHRA. Findings from the scoping heritage assessment suggested that the Magnetite Project is situated in a potentially sensitive Stone Age landscape. To adequately assess this component of the HIA, a Stone Age specialist was required as part of the Digby Wells team. The Terms of Reference and Scope of Work are discussed separately below.

2.1 Terms of Reference Digby Wells enlisted the services of a Stone Age expert to undertake specialist reconnaissance and report on relevant findings for the HIA of the proposed Magnetite Project.

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Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

2.2 Scope of Work The Scope of Work required as part of the Specialist Stone Age Assessment included: ■ Compilation of a desktop study providing detailed descriptions of the Stone Age within the local study area and determining the likelihood of Stone Age lithics and sites occurring within the proposed impact footprint; ■ Reconnaissance of the proposed project area based on the sensitivity analysis; ■ Identification and survey of landscape features where significant Stone Age sites may be expected; ■ A technical report based on the findings of the desktop study and reconnaissance that provided professional opinion regarding the significance of identified sites, the intensity of any possible impacts and recommendations for the conservation and mitigation of all identified Stone Age resources.

2.3 Project Limitations ■ The survey was conducted over four days and effort was made to cover as much of the project footprint area as possible in this short period of time. Our methodology was suitably constructed to ensure a comprehensive survey of the various sections within the project area. Some areas around the project area were also surveyed to help reconstruct site formation processes. ■ The vegetation of the project area is very dense and thorny, consisting mostly of Dichrostachys cinerea (Sickle Bush). Certain patches of the bush are impossible to get through and so exploration along transect paths was not always possible. Some sections also had thick grass making visibility of the ground poor. Consequently, it is possible that sites were missed. ■ Most archaeological accumulations and sites occur below the surface and do not leave an obvious trace above ground. Stone Age sites are especially hard to recognise and are often determined by geographical features, such as caves and shelters. Markers of Stone Age habitation sites are not easily recognised because the spatial features, such as hearths and activity areas, are not intrusive on a landscape. High of tools and debitage are usually the first indictors of a Stone Age site. Open air sites are easily disturbed, and especially so if in fluvial paths or next to agricultural lands or roads. These disturbances affect the stratigraphic integrity of the site and remove artefacts from any temporal or spatial context. Establishing any temporal or functional relationships between scatters of artefacts is difficult, especially so if the scatters cannot be related back to a high- density accumulation or site (Sutton, 2003). ■ Early Stone Age (ESA) assemblages are predominantly found in disturbed open-air habitation sites marked by high density scatters of stone tools and debitage. Many Middle Stone Age (MSA) and Later Stone Age (LSA) sites are found in rock shelters

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Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

and caves (Mitchell, 2002) but open air sites were also used. Open air Stone Age sites have been reported in the project region, such as in the Waterberg but are scarce. Rock shelters and caves offered protection from the elements and potential predators and presented fixed points in a landscape which could be habited (Mitchell, 2002). Shelters and caves also offer protection of the deposits after the site is abandoned, therefore improving preservation – allowing for the preservation of organic materials and less chance of the stratigraphy being disturbed.

3 Methodology

3.1 Qualitative Data Collection A diverse range of information repositories was reviewed to identify relevant and credible information sources about the Stone Age in the region. The objectives of this literature review were to: ■ Gain an understanding of the archaeological landscape within which the proposed project is located – including all ESA, MSA and LSA assemblages; ■ Identify any potentially sensitive areas; ■ Understand site formation processes in the region, so that any similar activities in the proposed impact footprint area of the Magnetite Project area can be identified.

Repositories used included the SAHRIS, various online / electronic journals and platforms, and resources at the Wits University libraries, including unpublished theses. All sources that were used are cited in the report.

3.2 Field Based Data Collection Field based data for the HIA was collected between 23 and 27 March 2015. The survey was focussed on the proposed impact footprint of the Magnetite Project based on the sensitivity analysis. The survey was conducted as an adaptive, non-intrusive (i.e. no sampling was undertaken) pedestrian survey to cover the large extent of the impact footprint within the allocated time. The footprint for Pit 2 and the Plant area were surveyed randomly to cover as much of the footprint as possible. The remaining infrastructure footprint areas were covered through systematic surveys. Transects1 running from east to west and measuring 150 m apart were plotted over the over the impact footprint for the Waste Rock Dump, Top Soil Dump and Pit 1. The northern and southern sections of these infrastructures were surveyed along these

1 Transects served as a guide to assist in the systematic survey of the impact footprints. It must be noted however that the natural topography and vegetation cover restricted movement through the landscape. While every attempt to adhere to transects was undertaken, this may not have been possible at all times.

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Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

transects. The Tailings Dam infrastructure was surveyed along transects running from north to south, spaced 150 m apart. The objectives of the survey were to: ■ Verify heritage resources identified during the scoping assessment; ■ Visually record the current state of the cultural landscape; ■ Confirm certain heritage features that have been identified in the literature; ■ Record all tangible heritage resources within the proposed impact footprint.

Identified heritage resources were recorded as waypoints using a handheld GPS and documented through written and photographic records. The area covered was recorded as a track log.

3.2.1 Stone Age Survey Methodology Archaeological sites are not only defined as areas distinguished by a collection of artefacts but also by looking at the spatial relationship between artefacts (Binford, 1964). Therefore in conducting an archaeological survey one has to consider off-site distributional data. Since no Stone Age sites where known in or around the project area an off-site approach was employed. This involves determining artefact distribution and variability in artefact density characteristics (Dunnell & Dancey, 1983). The survey was performed with the aim of identifying any archaeological accumulations and sites present in the project area as well as classifying any stone tools found. GPS readings were made at points where a higher density of artefacts were found, or any individual diagnostic tools. Find spots are labelled as low-density scatters if there are five or more stone tools with in a three-square meter area. Find spots and low density scatters do not necessarily contain complete, diagnostic or formal tools. Any diagnostic tools and features were recorded to aid in identification of Stone Age periods. At each find spot notes were made about the nature and density of the accumulation – stone tool types, raw material, the presence of pottery, archaeological features, landscape features and soil type. All material was considered within the regional, geological, environmental and historical contexts. Any geomorphological, biogenic and anthropogenic agents and processes – such as fluvial, colluvial or agricultural disturbances – which may have affected the distribution of the artefacts, were noted.

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Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

4 Regional Stone Age Landscape Description This section provides a description of the regional Stone Age landscape to assist in the assessment of identified Stone Age resources. The geological and fluvial landscape of the wider area is considered to help understand the nature of the accumulations found. ESA, MSA, LSA and Iron Age sites have been found in the region and throughout the Limpopo Province. Notably, the Makapan Valley WHS site is 45km south-east of the project area and the presence of any karst topography in the project area is considered.

4.1 Geological Landscape The project area is located on a part of the northern limb of the Bushveld Complex, where the ultramafic and rocks of the Rustenburg Layered Suite overlays a floor of Archaean basement , gneiss and schist to the east. To the west, the Rustenburg Layered Suite is overlain by Bushveld granite sills, namely the Lebowa Granite Suite and younger post Bushveld Waterberg Group and Quaternary cover rocks. The SAHRIS Palaeontological Sensitivity Map and Fossil Heritage Layers categorised the project area as of zero to moderate palaeontological significance (SAHRA, 2013). There are two exceptions to this rating: the Malmani Subgroup and Waterberg Group. The Malmani Subgroup dolomite formation, of the Chuniespoort Group of the Transvaal Supergroup, is dated to between ~2 600 Ma and ~2 500 Ma. The Waterberg Group is composed of conglomerate, quartzite and shale and erodes into the Bushveld Complex volcanic rocks. It is dated to ~ 1700 Ma. The Malmani Group dolomites feature stromatolites that contain the oldest evidence of cyanobacteria and hold to the potential for the development of karst topography and breccia formation. Karst topography refers to landscapes formed from the dissolution of soluble rocks, such as dolomite and limestone. Dissolution of these soluble Malmani dolomites created voids – sinkholes or caves – that filled with fine- to coarse-grained alluvium during periodic flooding. The alluvium may be represented by bodies of breccia, sandstone and siltstone which are likely to contain archaeological material. The dolomites are associated with the more extensive Makapan Valley World Heritage Site (WHS) karst landscape and therefore under possible protection. Cave of Hearths in the Makapan Valley WHS is the most significant example of a karst landscape in the region. The current study area is situated approximately 45 km north-west of the Makapan Valley WHS core area. A small section of this group was identified south-west of the region, outside of the project area.

4.2 Fluvial Processes Fluvial and colluvial action have affected the landscape in the area and the archaeological record. One of South Africa’s largest floodplain wetlands, the Nylsvlei, is located on the Nyl River between Modimolle and Mokopane. Nylsvlei is south of the project area with many tributaries within the wetland, but a well-defined river has reformed further down valley – the Mogalakwena. The Mogalakwena River and one of its tributaries, the Borobela, are the main

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Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

watercourses that run through the project region. The Mogalakwena River was once a bedrock river that changed into a fluvial river due to the flow transport capacity being outpaced by the sediment supply from its many tributaries (Colarossi D. , 2013; McCarthy, et al., 2011). It currently lies about six kilometres west of the project area. Global glacial and interglacial cycles directly affect sediment deposition and aggradation. Fine-grained (clay and silt) sediment accumulation along the tributaries is likely to have increased during periods where vegetation is reduced due to arid and cooler or warmer conditions (Colarossi D. , 2013; McCarthy, et al., 2011). Subsequent heavy rainfall generates large amounts of runoff water containing medium-coarse grained sediments resulting in additional tributary fan formation and progradation along the distal tributaries (McCarthy, et al., 2011).This ultimately resulted in the gradual westward migration of the river toward the Waterberg. Given the rivers current location and its gradual movement westwards it, and its tributaries, are likely to have modified the soil in the project area, depositing clayey soils and raw materials in its path. There are no tributaries or streams currently in the project footprint area, with the closest tributary, the Borobela, lying north-west of the project area. This tributary is a seasonal water source. It lies to the south-east of the villages of Bakenberg and Pudiakgopa, separating the villages and the project area.

4.3 Soils and Sediments There are three main soil types found in the project area – colluvium, vertic soils and an iron- rich, red soil. Colluvium is found near the base of Malokong Hill. It is a grey-white clayey soil containing a large coarse element such as rock fragments, pebbles, pieces of granite and calcrete. It is found in places at the base of the hill, sometimes forming eroded fluvial channels (Figure 4-1). The vertic soils, or vertisols, are easily identified by an intensively cracked surface. They are brown-grey clayey soils which have stones and pebbles lying on top of it (Figure 4-2). Vertic soils are shrink-swell formations formed by continual and intensive shrinking and swelling of sediments in wet and dry periods. This shrink and swell periods cause any friable soil components to become fragmented and fine particles are rearranged, forming cracks when dry (Courty, Goldberg, & Macphail, 1989). The coarse elements in the soil, such as rock fragments, cannot be fragmented and are pushed towards the soil surface, often getting deposited on the surface. This causes the sorting of stones and particles through the sediment, with stone fragments and pebbles being deposited on or near the surface, removed from their primary context. The bright red soil is accompanied by a slight change in vegetation with fewer bushes and more grassland. These soils are mostly found near areas that have been historically used for agriculture, and possibly indicate soil that was previously ploughed or cultivated. Large quantities of (unutilised) quartz and magnetite nodules are found in this soil (Figure 4-3).

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Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Figure 4-1: Eroded Calcrete, Fluvial Channel at the Base of Malokong Hill, outside of the Magnetite Project Impact Footprint Area

Figure 4-2: Cracked Vertic Soils found in the Magnetite Project Impact Footprint Area

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Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Figure 4-3: Bright Red Soil containing (unutilised) Quartz and Magnetite Nodules found in some areas of the Magnetite Project Impact Footprint Area

4.4 The Stone Age Stone Age tool use and technology is linked to the geological and hydrological features of the landscape. Raw materials used for stone tool production are selected from materials available on the landscape with fine-grained materials producing better tools that are easier to knap and create desired tool shapes and edges. Lithics identified during the initial reconnaissance of the project area were comprised of fine-grained felsic tuff, feldspars and quartz. The felsic tuff originates from the Rooiberg Group - a formation about 40 km away from the project area (Van der Ryst, 1996; Longridge, pers.comm.). Stone Age lithics are often identified in isolation and outside of discernible context, therefore providing limited information beyond form, function and technique of manufacture. Finding habitation sites, in caves and shelters, is therefore useful in reconstructing past subsistence strategies and landscape usage patterns.

4.4.1 Hominin evolution and the Early Stone Age ESA accumulations are dated between ~3 Ma to 300 Ka and diagnostic stone tools include simple core tools, handaxes and choppers. The most significant Stone Age sites in the region are found in a series of caves in the Makanpan Valley WHS. The Makapansgat Limeworks contain several fossil Australopithecus Africanus specimens, dated to about 3 mya (McFadden & Brock, 1984). An important ESA site in the Makapan Valley is Cave of Hearths. Cave of Hearths is part of a series of caves including Historic Cave or Makapansgat (containing Iron Age and historic material) and Hyena Cave (Latham & Herries, 2004). Cave of Hearths contains Acheulean lithics, characterised by (large) handaxes and cleavers. It marks also one of very few instances of rock-shelter Acheulean

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occupations and early and modern Homo remains (Pearson & Grine, 1997). The ESA accumulations are overlain by MSA and LSA accumulations. Large amounts of the lithic material (raw material as well as completed tools) found in the cave originates from elsewhere and had to have been transported into the cave by hominids. This implies that much wider hominid activity must exist within the region, including open air sites (Esterhuysen, 2003).

4.4.2 Middle Stone Age MSA accumulations to ~300 Ka to 30 Ka, with diagnostic stone tool identifiers including convergent flake scares, multi-faceted platforms, retouched points and backing. The MSA is associated with modern humans - Homo sapiens sapiens. Assemblages are characterised by refined lithic technologies such as prepared core techniques, retouched points and blades, which were produced from good quality raw material. The MSA assemblages portray changing behavioural patterns and indictors of cognitive abilities comparable to contemporary humans. Apart from lithic changes, other indicators of these advancements are through the control of fire, and the creation of compound adhesives for hafting stone tools (Wadley, Hodgskiss, & Grant, 2009). Development-driven archaeological studies report on MSA scatters near the project area (Pistorius, 2002; Kusel, 2005; Roodt, 2008). Many MSA sites are close to water sources, but not completely dependent on them (as they were in the ESA). Less dependency on water sources implies that people living in the MSA made use of water containers made of skin or ostrich eggs. People in the MSA were efficient hunters, hunting a range of large and medium game with stone-tipped spears. Their diet also included small mammals, such as duiker and bushpig, probably caught in traps and snares (Wadley, Were snares and traps used in the Middle Stone Age and does it matter? A review and a case study from Sibudu, South Africa, 2010). At habitation sites, where bones have preserved (usually shelters were organic preservation is good), many of the bones were burnt and smashed for marrow extraction, but species identification of the animals is still possible.

4.4.3 Later Stone Age The LSA dates to ~30 Ka to 2000 years ago. The LSA is characterised by a microlithic (bladelet) production technology, increased practice of ritual, long-distance movement and the widening of social relations, complex societies and rock art. Microlithics are produced from fine-grained cryptocrystallines, quartz and chert and were often hafted onto sticks for arrows. LSA communities practiced hunting and gathering subsistence strategies, exploiting a wide range of food sources and landscapes. The later part of the LSA is associated with autochthonous hunter-gatherer societies that include the San / Bushmen and Khoi herders. The most notable site in the region is associated with the LSA occupation at Makapansgat, one of the archaeological sites in the Makapan Valley WHS. LSA deposits have also been recorded at a site about 16 km south of the project area (Kusel, Cultural Heritage Resources Impact Assessment of the Farms Groothoek 220 KR, Nyhoffsbult 231 KR and Zwartkop 219

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Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

KR, Sterkrivier Naboomspruit, Limpopo, 2007) as well as in the Waterberg. The Waterberg contains a diverse range of rock art, from LSA, Iron Age and historic periods. The most prolific rock art of the Waterberg are the “Late White” finger paintings associated with the Late Iron Age (LIA).

2 5 Findings and Discussion The Magnetite Project impact footprint area is divided into a number of sections surrounded by a Berm - Pit 1, Pit 2, Top Soil Dump, Tailings Dam, Plant Area and Waste rock Dump site. I will use these sections in my site information to help distinguish GPS points and site locations. Scattered surface occurrences of MSA stone tools can be found spread across the sections of the proposed Magnetite project footprint area. Thirty-seven Stone Age find spots were identified, 17 of which could be described as low density scatters (i.e. five or more lithics found in a three-square meter area). The other 20 find spots indicate areas where either a diagnostic or retouched tool was found or where there was a slight increase in the number of stone tools but not significant enough to be called a low density scatter. The size of the find spots ranges from three to twenty meters and is mostly determined by the size of the clearing in vegetation ending where the density of the bush and grass increases. No medium to high density scatters were found. Most of the areas with these low density scatters are in visibly disturbed areas, e.g. near roads, in a distinct colluvial path or next to agricultural fields. No Stone Age sites were found, therefore no hearths or tool processing areas, and there is no visible organic preservation. All the stone tools are MSA. The stone tools are mainly flakes and flake fragments. Many flakes are endstruck and some flakes have retouch along the edges, usually irregular. Some tools have bifacial retouch, but it is irregular and erratic. In the whole project area, only one formal tool, a unifacial point, was found (Figure 5-1). A few cores and scrapers were found, and one hammerstone (Figure 5-1). Some tools are weathered but others are in good condition. Over 95% of the stone tools are made of felsic tuff - a fine-grained red-brown or red-orange material. This material originates from the Rooiberg Group formation that is roughly 40 km away from the project area (Van der Ryst, 1996; Longridge, pers.comm.). This raw material is likely to have been transported by geofluvial processes in the rivers and tributaries in the region, but may also serve as an indicator of long-distance raw material transportation. A few tools found in the project area are made of quartz, which is a local material found in the quartz veins within the Bushveld Complex. Small quartz nodules are readily available on the ground, but relatively few quartz lithics were found.

2 The discussion described the identified resources in relation to the proposed impact footprint based on the sensitivity analysis described in the Draft Heritage Impact Assessment (DHIA). The distribution of these resources is presented in Plan 1 in Appendix A. Revisions to the proposed Magnetite Project impact footprint subsequent to this report is not considered here. Please refer to the DHIA for the distribution of identified resources in relation to the final impact footprint.

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Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Many of the artefacts found in the project area were found in and around colluvial and fluvial paths (currently dry) and/or vertic soil. The brown-grey vertic soil is consistent with sediments formed from fluvial movement, probably from the gradual movement of the Mogalakwena’s tributaries across the landscape. Lithics can therefore not be placed in any temporal or spatial context.

a b

c d

Figure 5-1: Examples of some of the MSA Tools found in Magnetite Project Impact Footprint Area, all made from Felsic Tuff. a) Unifacial Point, b) Hammerstone, c) Radial Core, d) Irregular Flakes Colluvial movement, erosion and gravitational processes on the steep western side of Malokong Hill have affected the archaeological record in Pit 1 and the Waste Dump areas. These colluvial paths are clear in some places with eroded channels containing clayey yet gravel-rich, calcrete sediment. Close to the base of the hill low density artefact scatters (Stone Age and Iron Age) and are found along these channels. As these paths are followed away from the hill the soil becomes a brown-clayey vertic soil and artefacts become sparse. Near the western edge of the Waste Dump area, as one nears the agricultural fields, the soil changes to the red, silty soil containing quartz and magnetite nodules. A few low density scatters are found in areas that have been disturbed, by roads for example. As a whole, higher quantities of lithics are found in the Pit 1 and Waste Dump Rock areas than the other proposed areas of the mine. The colluvial and fluvial processes that occur(red) in the area

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present us with an incomplete and decontextualized archaeological record. There is no reason to suggest that any of these artefacts are found in their primary context. Although outside the project area, we attempted to find MSA sites on Malokong hill to determine the source of the lithics found at the base of the hill and in the project area. Most MSA and LSA sites are found in rock shelters and overhangs, which offer protection from inclement weather and wild animals, and also provide some protection to sediments post- deposition. No rock shelters were found on the western side of the hill. Not all areas could be reached due to dense vegetation and time constraints (especially with the hill being outside the project area and impact zone), but there are no obvious shelters visible on the hill. Hardly any tools or flake fragments were found on the hill - only a hammerstone and two flakes were found. The thick vegetation and thick grass made ground visibility poor and may contribute to the incredibly low numbers of Stone Age artefacts identified. Iron Age occupation is obvious on the hill, in the form of extensive stone walling and pottery. Iron Age settlements are likely to have disturbed Stone Age sites or accumulations. Areas disturbed by the granite (by Royal Granite Supplies Red (Pty) Ltd), such as roads or quarry sites, were explored with the expectation that the disturbance may have reveal Stone Age material. However, only three lithic artefacts were found. Kusel (2005) reported MSA material in small quantities on eastern side of Malokong Hill. The lack of any material on the hill is perhaps to be expected due to the absence of rock shelters and the steep slope of the hill. Stone Age habitation sites were more likely situated along the less steep areas near the base of the hill. Water and erosion would have still played a factor here moving these sediments further downhill. This is outside of project footprint area. Stone Age lithics were found scattered around the Tailings Dam, Pit 2 and Plant Areas of the proposed mine in small quantities. The low density scatters are located near the south end of the Tailings Dam and Pit 2 areas near agricultural fields. The soil in these areas is mostly red silty soil containing quartz and magnetite nodules.

6 Statement of Significance To provide a Statement of Significance for the Stone Age landscape and resources, the identified Stone Age accumulations located within the project area were assessed against select dimensions as applicable – aesthetic, historic, scientific and social. These were then measured against one or more descriptive attributes. This helps to indicate whether a resource should be included in the national estate as defined in the NHRA and international conventions. Find spots were categorised as lower density scatters if five or more stone tools were found with in a three-square meter area. Neither find-spots nor low density scatters necessarily contain complete, diagnostic or formal tools. In fact, very few formal tools were found during the survey. However, the stone flakes can still offer valuable information about the time period, flaking and percussion techniques, raw material choices, movement across a landscape and even population densities in the area. Sites with diagnostic tools or tool scatters that provide an array of information about the above mentioned aspects, do still hold

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Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

some importance and significance. This is because scientific and historic information can still be retrieved from the tools and the way they were produced, even though they are out of their primary context and their stratigraphic integrity has been lost. Table 7-2 in the HIA provides a summary of the Statement of Significance for the Stone Age cultural landscape in the Magnetite Project Area. The ratings provided in Table 7-2 show which aspects of each of the stone tool accumulations found during the survey could provide significant information. These have been evaluated according to their Aesthetic, Historic, Scientific, Social significance, integrity and value. The results of the assessment indicate that the Stone Age heritage resources within the Magnetite Project Area and surrounds are of negligible to low significance.

7 Conclusions and Specialist Recommendations Stone tools are found scattered around the Magnetite Project footprint area, but the primary depositional context of the lithic materials has been lost due to colluvial and fluvial movement and, in some areas, agriculture. The stone tools found in the project area are almost entirely informal tools, bearing little retouch. Many are flake fragments and some are badly weathered. The tools can provide information of form, function and technique of manufacture, but very little contextual and scientific information. Considering the Stone Age artefacts within the fluvial and geomorphic processes occurring in the area demonstrate that none of the material is in its primary context. Material is likely to have been spread around the landscape through various colluvial and fluvial processes (in Pit 1, the Waste Rock Dump site and the Plant Area), with fluvial processes of the Mogalakwena River and its tributaries affecting horizontal artefact redistribution around the landscape and the vertic nature of the clayey soils affecting vertical distribution. Artefact disturbances are further increased by Iron Age and historical use of the land. No Stone Age sites were identified within the project area. Stone tools are the only indicators that Stone Age populations lived in the area. No ancient bones were found, nor habitation sites. Results of the survey analysis indicate that of the 37 find spots identified as containing MSA material, only three deserve further investigation. These three sites are found along a colluvial, calcrete-rich path at the base of Malokong hill, outside of the project footprint area. Further exploration of the Malokong Hill – outside the project area, and outside of the scope of this project – will definitely contribute to the knowledge of the MSA habitation of the area and hopefully result in the identification of some sites. The survey was a comprehensive coverage of the Magnetite Project area. This project identified a large quantity of MSA material portraying extensive use of this area in the MSA. This may be of importance in understanding how people in the MSA utilized this landscape. However, the information that can be gained from the Magnetite Project footprint area is limited because artefacts are informal, are not within their primary context, and no habitation or factory sites were found. Based on my understanding of the cultural and geological landscape and the identified Stone Age artefacts within the project area, I have no objection to the proposed development.

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8 References Binford, L. R. (1964). A consideration of archaeological research design. American Antiquity, 29, 425-441. Chamber of Mines of South Africa/Coaltech. (2007). Guidelines for the Rehabilitation of Mined Land. Colarossi, D. (2013). Geology and geochronology of the Nyl River floodplain sediments, Limpopo Province, South Africa. University of the Witwatersrand: Unpublished MSc Thesis. Colarossi, D. (2013). Geology and geochronology of the Nyl River floodplain sediments, Limpopo Province, South Africa. University of the Witwatersrand: Unpublished MSc Thesis. Courty, M. A., Goldberg, p., & Macphail, R. (1989). Soils and Micromorphology in Archaeology. Cambridge: Cambridge University Press. Dunnell, R. C., & Dancey, W. S. (1983). The siteless survey: A regional scale data collection strategy. Advances in Archaeological Method and Theory, 8, 267-287. Esterhuysen, A. (2003). Phase 1 & Phase 2 Report Makapan Valley Project: Heritage and Archaeological Resources Development Project. University of the Witwatersrand: Unpublished Report. Fey, M., Hughes, J., Lambrechts, J., Dohse, T., Milewski, A., & Mills, A. (2010). Soils of South Africa. Cape Town, South Africa: Cambridge University Press. Klingebeiel, A., & Montgomery, P. (1961). Land Capability Classification. Agricultural Handbook No.210. Washington: USDA. Kusel, U. (2005). Cultural Heritage Resources Impact Assessment on Malokong Hill. African Heritage Consultants cc: Unpublished report (2005-SAHRA-0053). Kusel, U. (2007). Cultural Heritage Resources Impact Assessment of the Farms Groothoek 220 KR, Nyhoffsbult 231 KR and Zwartkop 219 KR, Sterkrivier Naboomspruit, Limpopo. African Heritage Consultants cc: Unpublished report (2007-SAHRA-0506). Land Type Survey Staff. (1972 - 2006). Land types of South Africa; Digital Map (1:250 000 scale) and Soil Inventory Database. Pretoria: ARC-Instatute for Soil, Climate, and Water. Latham, A., & Herries, A. I. (2004). The Formation and Sedimentary Infilling of the Cave of Hearths and Historic Cave Complex, Makapansgat, South Africa. Geoarchaeology: An International Journal, 19(4), 323-342. Longridge, L. (pers.comm.). pers.comm. McCarthy, T. S., Tooth, S., Jacobs, Z., Rowberry, M. D., Thompson, M., Brandt, D., et al. (2011). The origin and development of the Nyl River floodplain wetland, Limpopo

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Province, South Africa: trunk–tributary river interactions in a dryland setting. South African Geographical Journal, 93(2), 172-190. McCarthy, T. T. (2011). The origin and development of the Nyl River floodplain wetland, Limpopo Province, South Africa: trunk–tributary river interactions in a dryland setting. South African Geographical Journal, 93(2), 172-190. McFadden, P. L., & Brock, A. (1984). Magnetostratigraphy at Makapansgat. South African Journal of Science, 80, 482-483. Mitchell, P. (2002). The Archaeology of Southern Africa. Cambridge: Cambridge University Press. Nel, J., Murray, K., Maherry, A., Peterse, n. C., Roux, D., Driver, A., et al. (2011). Technical Report for the National Freshwater Ecosystem Priority Areas project. WRC report No. 1801/2/11, Water Research Commission. Partridge, T. (1997). Cainzoic environmental change in southern africa, with special emphasis on the last 200 000 years. Progress in Physical Geography, 21, 3-22. Pearson, O. M., & Grine, F. E. (1997). Re-analysis of the hominid radii from Cave of Hearths and Klasies River Mouth, South Africa. Journal of Human Evolution, 32, 577-592. Pistorius, J. C. (2002). A Cultural Heritage Impact Assessment for the Proposed Overysel Zwartfontein (PPRust North) Project. Amendment to Potgietersrust Platinums Ltd's (PPRust) Environmental Management Programme Report (EMPR). SRK Consulting: Unpublished report (2002-SAHRA-0085). Roodt, F. (2008). Phase 1 Heritage Resources Impact Assessment: Landfill and Salvage Yard Anglo Platinum Mogalakwena Section, Limpopo. Cultural Resources Consultants: Unpublished report (2008-SAHRA-0529). SAHRA. (2013, 10 29). Archaean Granite-Gneiss Basement. Retrieved July 1, 2015, from South African Heritage Resources Agency: http://www.sahra.org.za/fossil- layers/archaean-granite-gneiss-basement SASA, S. A. (1999). Identification & management of the SOILS of the South African sugar industry. Mount Edgecombe: South African Sugar Association Experiment Station. Schoeman, J. L., Van der Walt, M., Monnik, K. A., Thackrah, A., Malherbe, J., & Le Roux, R. E. (2000). The Development and Application of a Land Capability Classification System for South Africa. ARC-Institute for Soil, Climate and Water. Pretoria: ARC- ISCW report no GW/A/2000/57. Schoeman, J. L., Van der Walt, M., Monnik, K. A., Thackrah, A., Malherbe, J., & Le Roux, R. E. (2000). The Development and Application of a Land Capability Classification System for South Africa. ARC-Institute for Soil, Climate and Water. Pretoria: ARC- ISCW report no GW/A/2000/57. Smith, B. (2006). The Farming Handbook. Netherlands & Southafrica: University of KwaZulu-Natal Press & CTA.

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Soil Classification Working Group. (1991). Soil Classification A Taxonomicsystem for South Africa. Pretoria: The Department of Agriculturel Development. Soil Classification Working Group. (1991). Soil Classification A Taxonomicsystem for South Africa. Pretoria: The Department of Agriculturel Development. Sutton, M. (2003). A survey forthe Middle Stone Age sites on Parma Farm, Limpopo River Basin. University of the Witwatersrand: Unpublished MA Research Report. Van der Ryst, M. M. (1996). The Later Stone Age prehistory of the Waterberg, with special reference to Goergap shelter. University of the Witwatersrand: Unpublished MA thesis. Wadley, L. (2010). Were snares and traps used in the Middle Stone Age and does it matter? A review and a case study from Sibudu, South Africa. Journal of Human Evolution, 58, 179-192. Wadley, L., Hodgskiss, T., & Grant, M. (2009). Implications for complex cognition from the hafting of tools with compound adhesives in the Middle Stone Age, South Africa. Proceedings of the National Academy of Sciences, 106(24), 9590-9594.

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Appendix A: Declaration of Independence

Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

University of the Witwatersrand

Contact person: Tammy Hodgskiss

Evolutionary Studies Institute Tel: 083 688 3478 University of the Witwatersrand Fax: -

1 Jan Smuts Avenue E-mail: [email protected] 2050

I, Tammy Hodgskiss as duly authorised representative of Digby Wells and Associates (Pty) Ltd., hereby confirm my independence (as well as that of Digby Wells and Associates (Pty) Ltd.) and declare that neither I nor Digby Wells and Associates (Pty) Ltd. have any interest, be it business, financial, personal or other, in any proposed activity, application or appeal in respect of VM Investment Company or Pamish Investment No. 39 (Pty) Ltd, other than fair remuneration for work performed, specifically in connection with the Heritage Resources Management (HRM) Process for the proposed Magnetite Project, Limpopo Province.

Full name: Tammy Hodgskiss Title/ Position: Specialist Sub-contractor: Stone Age Archaeologist Qualification(s): PhD in Archaeology Experience (years): 8 years Registration: Association of Southern African Professional Archaeologists (ASAPA)

Stone Age Report Proposed Open Pit Magnetite Mine and Concentrator Plant, Mokopane, Limpopo Province VMC3049

Appendix B: Plans

28°47'0"E 28°48'0"E 28°49'0"E 28°50'0"E

SA-006 Plan 1

Pit 1 129 ha FC-023 Pamish Investments SA-024 SA-022 SA-021 SA-025 O OR Magnetite Mine EIA B Top Soil FC-035 SA-020 Dump Impact Footprint Assessed 29 ha FC-018 SA-034 SA-036 SA-037 & Identified Sites SA-007 SA-006 23°52'0"S 23°52'0"S SA-049

SA-019 SA-033 SA-028 SA-027 FC-026 FC-023 SA-022 SA-004 SA-020 Malokongskop Legend FC-035 SA-036 SA-005 SA-034 SA-030 SA-031 SA-029 SA-033 SA-049 Project Area FC-003 SA-019 SA-009 SA-032 SA-004 SA-005 Settlement SA-010 FC-003 Main Road

Waste Mothoathoase Minor Road Rock Dump

220 ha Track SA-038

SA-039 SA-041 SA-040 Non-Perennial Stream

SA-042

SA-043 Dam Wall FC-011 Basogadi FC-002 23°53'0"S SA-012 23°53'0"S Dam / Lake Pit 1 129 ha Proposed Infrastructure

Berm

Haul Road

Proposed Infrastructure

Tailings Dams 69 ha

FC-048

SA-013 SA-045 Plant Area SA-044 FC-014 62 ha 23°54'0"S 23°54'0"S

Ditlotswana

Pit 2

66 ha

Identified Heritage Resources

SA-047 Farming Community

Sustainability Service Positive Change Professionalism Future Focused Integrity Stone Age SA-016 BGG-001 Projection: Transverse Mercator Ref #: scm.VMC3049.201506.159 SA-015 Datum: WGS 1984 Revision Number: 1 Heritage Tracks SA-046 Central Meridian: 29°E Date: 18/06/2015

Burial Ground & Graves 0 0.25 0.5 1

Farming Community Kilometres 23°55'0"S 23°55'0"S 1:25 000

www.digbywells.com © Digby Wells Environmental 28°47'0"E 28°48'0"E 28°49'0"E 28°50'0"E