Palaeontological Impact Assessment May Be Significantly Enhanced Through Field Assessment by a Professional Palaeontologist

PALAEONTOLOGICAL HERITAGE ASSESSMENT – DESKTOP STUDY:

Proposed development of an Interpretive Centre on the farm Nieuwe Kloof 202 in the Baviaanskoof World Heritage Site, Willowmore District, Eastern Cape

John E. Almond PhD (Cantab.) Natura Viva cc, PO Box 12410 Mill Street, Cape Town 8010, RSA [email protected]

August 2019

EXECUTIVE SUMMARY

Two site options on Farm Nieuwe Kloof 202 in the Bavaainsklof World Heritage Site, Willowmore District, Eastern Cape, are under consideration for a proposed new Interpretive Centre. Ordovician-aged fluvial bedrocks of the Peninsula Formation (Table Mountain Group) as well as the overlying Late Caenozoic colluvial or alluvial deposits at the preferred Alternative 1 site are all of low palaeontological sensitivity. The bedrocks here lie close to or within the major Baviaanskloof Fault Zone and are probably deformed and brecciated (fractured in situ), further compromising fossil preservation. The impact significance of the proposed Interpretive Centre on fossil heritage resources in the Baviaanskloof WHS is considered to be VERY LOW in the case of the preferred Alternative 1 site.

The highly-disturbed Late Caenozoic alluvium mapped at surface at the Alternative 2 site is likewise of low palaeontological sensitivity. However, satellite images suggest that potentially- fossiliferous Mesozoic sediments of the Uitenhage Group might occur here at depth, close to or beneath the site, since they are well-exposed on the southern flanks of the Baviaanskloof immediately to the south. Potentially-fossiliferous mudrocks of the Late Ordovician Cederberg Formation mapped just to the north of the Alternative 2 site are probably mantled by thick superficial deposits (colluvium / alluvium / soils) and so are unlikely to be directly affected by the proposed development (e.g. upgrading of access roads). On a precautionary basis, the impact significance of the proposed Interpretive Centre on fossil heritage resources in the Baviaanskloof WHS in the case of the Alternative 2 site is considered to be MEDIUM. There is therefore a preference on palaeontological heritage grounds for the Alternative 1 site which is already preferred on other grounds. However, the stratigraphy and palaeontological sensitivity of the two site options can only be accurately assessed through fieldwork. Confidence levels for this study are accordingly rated as only MODERATE.

It is recommended that, pending the potential discovery of significant new fossil remains during construction of the Baviaanskloof WHS Interpretive Centre development:  An exemption from further specialist palaeontological studies and mitigation should be granted if the Alternative 1 site is chosen;  A pre-construction site visit by a suitably qualified palaeontologist should be commissioned by the developer if the Alternative 2 site is chosen. The palaeontologist concerned should record any fossil heritage resources within the development footprint or its vicinity and

John E. Almond (2019) 1 Natura Viva cc submit a specialist report to ECPHRA with recommendations for any monitoring or mitigation measured relevant to the construction phase.

In either case, any substantial fossil remains (e.g. fossil shells, petrified wood or plant remains, vertebrate bones, teeth) encountered during the construction phase of the development should be reported by the ECO to the Eastern Cape Provincial Heritage Resources Agency, ECPHRA (Contact details: Mr Sello Mokhanya, 74 Alexander Road, King Williams Town 5600; [email protected]) for possible mitigation by a professional palaeontologist. A tabulated Chance Fossil Finds Procedure is appended to this report.

1. OUTLINE OF PROPOSED DEVELOPMENT

The Eastern Cape Parks and Tourism Agency (ECPTA) is proposing to develop an Interpretive Centre to be situated on the farm Nieuwe Kloof 202 in the western section of the Baviaanskloof Nature Reserve and World Heritage Site (WHS), Willowmore District, Eastern Cape Province (Fig. 1). The two site options for the Interpretive Centre under consideration - Alternative 1 (the preferred option) and Alternative 2 - are both located some 30 km SE of Willowmore and close to the unpaved R332 road near to where it enters the Baviaanskloofrivier Valley from the northwest via the Nuwekloof Gorge (Fig. 2).

The main infrastructural components of the proposed development include:

 An information centre, gallery, conference room, admin area, reception area and curio shop;  Staff areas, kitchen, scullery, store room and female and male toilets;  Walkways and decks made from hardwood;  Water, electrical and sewer services; and  Roads, parking bays and a guard house.

The Baviaanskloof study region is underlain by potentially fossiliferous rocks of Palaeozoic, Mesozoic and Caenozoic age. The present desktop palaeontological heritage assessment forms part of a Basic Assessment for the proposed development under the NEMA EIA Regulations of 2014 (as amended) that has been commissioned by MBSA Consulting, East London (Contact details: Mr Bathini Vanqa. MBSA Consulting, MBSA House, 8 Pine Park Street, Vincent, East London, RSA. Tel: 043 726 6513; E-Mail: [email protected]).

1.1. Legislative context

This report falls under Sections 35 and 38 (Heritage Resources Management) of the South African Heritage Resources Act (Act No. 25 of 1999), and it will also inform the Environmental Management Plan for this project.

The various categories of heritage resources recognised as part of the National Estate in Section 3 of the National Heritage Resources Act include, among others:

 geological sites of scientific or cultural importance;  palaeontological sites;

John E. Almond (2019) 2 Natura Viva cc  palaeontological objects and material, meteorites and rare geological specimens.

According to Section 35 of the National Heritage Resources Act, dealing with archaeology, palaeontology and meteorites: (1) The protection of archaeological and palaeontological sites and material and meteorites is the responsibility of a provincial heritage resources Agency. (2) All archaeological objects, palaeontological material and meteorites are the property of the State. (3) Any person who discovers archaeological or palaeontological objects or material or a meteorite in the course of development or agricultural activity must immediately report the find to the responsible heritage resources Agency, or to the nearest local Agency offices or museum, which must immediately notify such heritage resources Agency. (4) No person may, without a permit issued by the responsible heritage resources Agency— (a) destroy, damage, excavate, alter, deface or otherwise disturb any archaeological or palaeontological site or any meteorite; (b) destroy, damage, excavate, remove from its original position, collect or own any archaeological or palaeontological material or object or any meteorite; (c) trade in, sell for private gain, export or attempt to export from the Republic any category of archaeological or palaeontological material or object, or any meteorite; or (d) bring onto or use at an archaeological or palaeontological site any excavation equipment or any equipment which assist in the detection or recovery of metals or archaeological and palaeontological material or objects, or use such equipment for the recovery of meteorites. (5) When the responsible heritage resources Agency has reasonable cause to believe that any activity or development which will destroy, damage or alter any archaeological or palaeontological site is under way, and where no application for a permit has been submitted and no heritage resources management procedure in terms of section 38 has been followed, it may— (a) serve on the owner or occupier of the site or on the person undertaking such development an order for the development to cease immediately for such period as is specified in the order; (b) carry out an investigation for the purpose of obtaining information on whether or not an archaeological or palaeontological site exists and whether mitigation is necessary; (c) if mitigation is deemed by the heritage resources Agency to be necessary, assist the person on whom the order has been served under paragraph (a) to apply for a permit as required in subsection (4); and (d) recover the costs of such investigation from the owner or occupier of the land on which it is believed an archaeological or palaeontological site is located or from the person proposing to undertake the development if no application for a permit is received within two weeks of the order being served.

Minimum standards for the palaeontological component of heritage impact assessment reports (PIAs) have recently been published by SAHRA (2013).

John E. Almond (2019) 3 Natura Viva cc N

10 km

Figure 1: Excerpt from 1: 250 000 scale topographical sheet 1: 3322 Oudtshoorn (Courtesy of the Chief Directorate: National Geo-spatial Information, Mowbray) showing the location of the Baviaanskloof WHS Interpretive Centre project area on the farm Nieuwe Kloof 202, situated c. 30 km SW of Willowmore in the western section of the Baviaanskloof Nature Reserve, Willowmore District, Eastern Cape Province (black rectangle).

John E. Almond (2019) 4 Natura Viva cc GT Saagkuilskloof Op

Nuwekloof

alluvium UH3

Baviaanskloofrivier

UH2 UH2

UH1 UH1

Figure 2: Google Earth© satellite image of the western Baviaanskloof study area on the Farm Nieuwe Kloof 202, Willowmore District, Eastern Cape, showing the preferred and alternative sites for the proposed Interpretive Centre. Features of geological / palaeontological interest in the area include: resistant-weathering, steeply-dipping quartzites of the Goudini Formation (Sg) and Peninsula Formation (Op) of the Table Mountain Group building the S and N sides of the Baviaanskloof Valley; outcrop area (in shadow) of the mudrock-dominated Cederberg Formation, Table Mountain Group (Oc); varied N-dipping continental facies of Uitenhage Group (UH1-UH3); silcretes, possibly gravelly, of the Tertiary Grahamstown Formation capping planed-off pediment surfaces either side of the valley (GT); Late Caenozoic alluvium of the Baviaanskloofrivier flooring the valley. Deeply-incised, steep-walled gorges or klowe such as Nuwekloof and Saagkuilskloof characterise the Baviaanskloof region. The dashed line indicates the approximate trace of the major Cango-Baviaanskloof-Gamtoos Fault, with down-throw to the south and southeast, which shows a sharp bend near Nuwekloof (See also the geological maps in Figures 3 & 4). Scale bar = 800 m. N towards the top of the image.

John E. Almond (2019) 5 Natura Viva cc 2. APPROACH TO THE PALAEONTOLOGICAL HERITAGE ASSESSMENT

The information used in this desktop study was based on the following:

1. A draft Basic Assessment Report prepared by CES (April 2019), maps and kmz files provided by MBSA Consulting, East London; 2. A review of the relevant scientific literature, including published geological maps, satellite images, and previous palaeontological heritage assessments in the broader Baviaanskloof - Willowmore – Patensie region (e.g. Almond 2010b, 2013, 2019); 3. The author’s database on the formations concerned and their palaeontological heritage (Almond et al. 2008).

In preparing a palaeontological desktop study the potentially fossiliferous rock units (groups, formations etc) represented within the study area are determined from geological maps and satellite images. The known fossil heritage within each rock unit is inventoried from the published scientific literature, previous palaeontological impact studies in the same region, and the author’s field experience (Consultation with professional colleagues as well as examination of institutional fossil collections may play a role here, or later following field assessment during the compilation of the final report). This data is then used to assess the palaeontological sensitivity of each rock unit to development. The potential impact of the proposed development on local fossil heritage is then determined on the basis of (1) the palaeontological sensitivity of the rock units concerned and (2) the nature and scale of the development itself, most significantly the extent of fresh bedrock excavation envisaged. When rock units of moderate to high palaeontological sensitivity are present within the development footprint, a Phase 1 field assessment study by a professional palaeontologist is usually warranted to identify any palaeontological hotspots and make specific recommendations for any mitigation required before or during the construction phase of the development.

On the basis of the desktop and Phase 1 field assessment studies, the likely impact of the proposed development on local fossil heritage and any need for specialist mitigation are then determined. Adverse palaeontological impacts normally occur during the construction rather than the operational or decommissioning phase. Phase 2 mitigation by a professional palaeontologist – normally involving the recording and sampling of fossil material and associated information (e.g. sedimentological data) may be required (a) in the pre-construction phase where important fossils are already exposed at or near the land surface and / or (b) during the construction phase when fresh fossiliferous bedrock has been exposed by excavations. To carry out mitigation, the palaeontologist involved will need to apply for a palaeontological collection permit from the relevant heritage management Agency, i.e. the Eastern Cape Provincial Heritage Resources Agency, ECPHRA (Contact details: Mr Sello Mokhanya, 74 Alexander Road, King Williams Town 5600; Email: [email protected]). It should be emphasized that, providing appropriate mitigation is carried out, the majority of developments involving bedrock excavation can make a positive contribution to our understanding of local palaeontological heritage.

2.1. Assumptions & limitations

The accuracy and reliability of palaeontological specialist studies as components of heritage impact assessments are generally limited by the following constraints: 1. Inadequate database for fossil heritage for much of the RSA, given the large size of the country and the small number of professional palaeontologists carrying out fieldwork here. Most development study areas have never been surveyed by a palaeontologist.

John E. Almond (2019) 6 Natura Viva cc 2. Variable accuracy of geological maps which underpin these desktop studies. For large areas of terrain these maps are largely based on aerial photographs alone, without ground-truthing. The maps generally depict only significant (“mappable”) bedrock units as well as major areas of superficial “drift” deposits (alluvium, colluvium) but for most regions give little or no idea of the level of bedrock outcrop, depth of superficial cover (soil etc), degree of bedrock weathering or levels of small-scale tectonic deformation, such as cleavage. All of these factors may have a major influence on the impact significance of a given development on fossil heritage and can only be reliably assessed in the field. 3. Inadequate sheet explanations for geological maps, with little or no attention paid to palaeontological issues in many cases, including poor locality information; 4. The extensive relevant palaeontological “grey literature” - in the form of unpublished university theses, impact studies and other reports (e.g. of commercial mining companies) - that is not readily available for desktop studies; 5. Absence of a comprehensive computerized database of fossil collections in major RSA institutions which can be consulted for impact studies. A Karoo fossil vertebrate database is now accessible for impact study work. In the case of palaeontological desktop studies without supporting Phase 1 field assessments these limitations may variously lead to either: (a) underestimation of the palaeontological significance of a given study area due to ignorance of significant recorded or unrecorded fossils preserved there, or (b) overestimation of the palaeontological sensitivity of a study area, for example when originally rich fossil assemblages inferred from geological maps have in fact been destroyed by tectonism or weathering, or are buried beneath a thick mantle of unfossiliferous “drift” (soil, alluvium etc). Since most areas of the RSA have not been studied palaeontologically, a palaeontological desktop study usually entails inferring the presence of buried fossil heritage within the study area from relevant fossil data collected from similar or the same rock units elsewhere, sometimes at localities far away. Where substantial exposures of bedrocks or potentially fossiliferous superficial sediments are present in the study area, the reliability of a palaeontological impact assessment may be significantly enhanced through field assessment by a professional palaeontologist.

In the case of the Baviaanskloof WHS project area the main limitation for fossil heritage assessments is the lack of field-based geological and palaeontological studies in the region. The stratigraphy, age and palaeontology of the Mesozoic bedrocks along the Baviaanskloof Valley are poorly understood (Muir 2018, R. Muir, pers. comm., 2019). Confidence levels for this study are accordingly rated as only MODERATE.

3. GEOLOGICAL CONTEXT

The Baviaanskloof WHS is situated within the geologically complex eastern branch of the Cape Fold Belt. The western sector of the kloof runs west-east along the valley of the Baviaanskloofrivier between the rugged uplands of the Baviaanskloofberge in the north and the Kougaberge in the south. The geology of the region is shown on 1: 250 000 geological sheet 3322 Oudtshoorn (Council for Geoscience, Pretoria; Toerien 1979) (See Figs. 2 to 4). The study area is underlain at depth by fluvial to marine (and possibly glacial) beds of the Table Mountain Group (Thamm & Johnson 2006). These include (1) the Ordovician Peninsula Formation (Ope) with fluvial quartzites dipping steeply north on the northern side of the kloof, (2) the Silurian Goudini Formation (Sg) fluvial to shallow marine quartzites dipping to the south on the southern side of the kloof, and (3) the mudrock-dominated late Ordovician Cederberg Formation (Oc). This last unit is mapped along the northern edge of the main kloof to the west of Nuwekloof. It is recessive

John E. Almond (2019) 7 Natura Viva cc weathering and probably poorly-exposed here. Whether or not thin glacial beds of the Pakhuis Formation are present at its base is unclear. Potentially-fossiliferous mudrocks of the Cederberg Formation mapped to the north of the Alternative 2 site (Fig. 4) are probably mantled by thick superficial deposits (colluvium / alluvium / soils) and so are unlikely to be directly affected by the proposed development (e.g. upgrading of access roads).

To the north of the Baviaanskloof runs the trace of a major low angle reverse fault of Cape age, the Baviaanskloof Thrust, along which the Table Mountain Group succession has been thrust several kilometres to the north, in part over younger Bokkeveld Group rocks (Theron 1969, Booth et al. 2004). Further south the Cango-Baviaanskloof-Gamtoos Fault is a major normal fault with downthrow to the southeast and south whose trace runs along the northern edge of Baviaanskloof and makes a sharp bend close to Nuwekloof. This fault or fault zone is probably a re-activated pre- Cape basement structure of Mesozoic age.

While the Baviaanskloof Fault was active during the Jurassic and Cretaceous Periods, a thick prism of continental red beds of the Uitenhage Group (Ke) was deposited in the resulting half- graben (Baviaanskloof Basin) along the western sector of the kloof (Shone 2006). These red beds, whose northwards dip towards the Baviaanskloof Fault suggests synsedimentary deposition, have been provisionally referred to the Enon Formation by some authors but may compare more closely in tectonic setting, facies and age with the Kirkwood and Buffelskloof Formations (cf Toerien 1974, Muir et al. 2017a, Muir 2018). Satellite images of the western Baviaanskloof Basin suggest that a range of contrasting sedimentary facies are represented within the Uitenhage Group beds here which may interfinger with one another. As seen in Figure 2, these facies packages include, in stratigraphic order: (1) recessive-weathering (extensively gullied) greyish to orange- hued, well-bedded sediments broadly resembling the “variegated” beds of the fluvial to lacustrine Kirkwood Formation (UH1); (2) well-bedded, orange-hued, more resistant-weathering facies with a few, thin cliff-forming units (UH2); an uppermost pale grey package with some rugged- weathering subunits as well as more recessive-weathering beds building smoother slopes (UH3). Good hillslope exposures of the first two facies are seen within an interval of 500 m due south of the Alternative 2 Site and may even underlie the latter. Relict outcrops of the uppermost greyish- weathering package locally extend most, or perhaps all, the way across the Baviaanskloof (e.g. east of the preferred Alternative 1 Site) and might build the low elevation just west of the Alternative 2 Site. It is likely that the little-studied Uitenhage Group succession preserved in the Baviaanskloof broadly parallels that seen along the southern side of the Cango Fault in the Little Karoo (Oudtshoorn Basin). The red beds seen along the Baviaanskloof may therefore be stratigraphically equivalent in terms of facies and age to the Enon, Kirkwood as well as Buffelskloof Formations of Late Jurassic to Early Cretaceous age (cf Muir et al. 2017a, 2017b, Muir 2018).

The upland areas built by tough Table Mountain Group quartzites on both flanks of the Baviaanskloof have been widely planed-off by post-Gondwana erosion to form gently-sloping pediment surfaces that cut sharply across the steep bedding and dip towards the main valley (Fig. 2). Relicts of these upland pediments, which may be of Late Cretaceous to Neogene age, are preserved between several deeply-incised, steep-sided klowe such as Nuwekloof and Saagkuilenskloof. These narrow gorges, so typical of the Bavaainskloof WHS, were carved by tributary streams of the Baviaanskloofrivier during episodes of Caenozoic continental uplift. Locally small relict patches of silcretes and ferricretes (Fe) assigned to the Grahamstown Formation are preserved on the upland interfluves; they probably cement fluvial and colluvial sands and High Level Gravels of Tertiary age. The floor of the Baviaanskloof is mantled by much younger Late Caenozoic alluvial deposits (silts, sands, gravels) and soils derived from them with prisms of colluvial gravels (scree, sheetwash) along the valley margins. As seen in satellite images (Fig. 2)

John E. Almond (2019) 8 Natura Viva cc these superficial sediments and soils have been extensively disturbed by agricultural activities, tracks and farm buildings.

According to the Draft BAR for the Baviaanskloof Interpretive Centre project produced by CES (April 2019) (Fig. 4) the preferred Site Alternative 1 located near the mouth of Saagkuilenkloof is underlain by alluvial valley deposits and whitish-weathering quartz sandstone of the Peninsula Formation, with a vegetation cover of undisturbed fynbos and shrubland. Site Alternative 2 overlies previously cultivated alluvial valley deposits. As discussed earlier, it is also possible that Mesozoic sediments of the Uitenhage Group underlie Site Alternative 2 at depth. Both sites lie between 845 to 865 m amsl and are gently sloping.

5 km

Figure 3: Extract from 1:50 000 geological map 3325CD & 3425AB Uitenhage (Council for Geoscience, Pretoria) showing the approximate location of the Alternative 1 (red dot) and Alternative 2 (yellow dot) site options for the Baviaanskloof WHS Interpretive Centre. The main rocks units mapped here include: Middle to Late Ordovician Peninsula Formation (Op, pale purple); Late Ordovician Cederberg Formation (Oc, dark purple); Silurian Goudini Formation (St, middle puple); undifferentiated Uitenhage Group (Ke, orange); Grahamstown Formation silcretes and ferricretes (yellow with fine stipple); Late Caenozoic alluvium (yellow with flying bird symbol).

John E. Almond (2019) 9 Natura Viva cc Site Alternative 1

Site Alternative 2

Figure 4: Detailed geological map of the Interpretive Centre study area in the western part of the Baviaanskloof showing the approximate location of Site Alternatives 1 and 2 (Figure abstracted from the Draft Basic Assessment Report by CES, April 2019). Potentially- fossiliferous mudrocks of the Cederberg Formation (purple) mapped to the north of the Alternative 2 site are probably mantled by thick superficial deposits (colluvium / alluvium / soils) are so are unlikely to be directly affected by the proposed development (e.g. upgrading of access roads). Satellite images (cf Fig. 2) suggest that the outcrop area of the Uitenhage Group (pale green, labelled Enon conglomerate in the figure legend) may in fact extend up to, or even beneath, the Alternative 2 site.

4. PALAEONTOLOGICAL HERITAGE

Fossil taxa recorded from the sedimentary rock units mapped at or close to the alternative sites for the Baviaanskloof Interpretive Centre are briefly outlined in this section of the report.

 Table Mountain Group

Body fossils (shells, teeth, bones etc) are so far unknown from the Middle to Late Ordovician Peninsula Formation but a modest range of shallow marine to nearshore fluvial and / or estuarine trace fossils have been recognised, mainly from the Western Cape outcrop area (e.g. Rust 1967, Potgieter & Oelofsen 1983, Broquet 1990, 1992, Almond 1998a,b, Braddy & Almond 1999, Thamm & Johnson 2006). These traces include trilobite resting and feeding burrows (Cruziana, Rusophycus), arthropod trackways (e.g. Diplichnites, Palmichnium) that are variously attributed to eurypterids, crustaceans or trilobites, palmate, annulated feeding burrows (Arthrophycus), dense assemblages (“pipe rock”) of vertical dwelling burrows of unknown suspension feeders (Skolithos, Trichichnus), vertical columns or cones of densely reworked sediment (Metaichna / possible

John E. Almond (2019) 10 Natura Viva cc Heimdallia), and several types of horizontal burrows (Palaeophycus, possible Aulichnites). An important, albeit low diversity, assemblage of Peninsula Formation trace fossils was recently recorded from heterlithic beds to the southwest of Humansdorp by Almond (2012). Traces here include vertical Skolithos burrows, Rusophycus and Cruziana arthropod scratch burrows that were probably generated by trilobites, possible bivalve burrows (Lockeia) and teichichnoid spreiten burrows, as well as abundant flower-shaped “gyrophyllitid” burrows that had previously been reported from beach boulders at Cape Saint Francis. Recessive weathering of trace-rich heterolithic intervals is undoubtedly responsible for under-recording of fossils within the Peninsula Formation. It is also likely that relatively unweathered samples of fine-grained muddy sediments within these heterolithic intervals may eventually yield microfossil assemblages (e.g. organic- walled acritarchs) of biostratigraphic and palaeonvironmental significance.

The laminated carbonaceous shales of the Late Ordovician Cederberg Formation are famous for their diverse post-glacial biota of fossil invertebrates and jawless fish, some of which display exceptional soft tissue preservation (e.g. Cocks & Fortey 1986, Aldridge et al. 1994, 2001, Selden & Nudds 2004). So far this biota has only been recorded from the formation’s Western Cape outcrop area, however.

 Uitenhage Group

As previously indicated in Section 3, the stratigraphic affiliation of the various Uitenhage Group red beds represented in the western Baviaanskloof remains unclear, pending further fieldwork and the discovery of possible fossils and datable tuff horizons (volcanic ashes). Correlatives of the Late Jurassic to Early Cretaceous Kirkwood and Buffelskloof Formations may be exposed just to the south of the Alternative 2 site.

The Kirkwood Formation is the most palaeontologically productive unit in southern Africa that yields terrestrial biotas of Early Cretaceous age. Its overall palaeontological sensitivity is rated as high (Almond et al. 2008). Fossils include vascular plants (including concentrations of petrified logs, leaves and twigs, lignite beds, charcoal), tetrapod vertebrates (notably dinosaurs) and freshwater invertebrates, among others (Du Toit 1954, McLachlan & McMillan 1976, Muir et al. 2017b). Recent palaeontological research has yielded a number of new dinosaur taxa, for the most part from the Algoa Basin to the northeast of Port Elizabeth, but also from the Oudtshoorn Basin of the Little Karoo (De Klerk 2008) and the Vleesbaai Basin.

Thin (≤ 5 cm), lenticular lignite layers and carbonaceous clays with yellowish amber, ferruginous concretions as well as sandstones containing plant fossils (e.g. carbonaceous stem compressions), but apparently no petrified wood, have been reported from Kirkwood Formation from two localities near Loerie, in the south-eastern Gamtoos Basin (Rogers 1906, Haughton et al. 1937 pp 28-29, Du Toit 1954 p. 379, McLachlan & McMillan 1976 pp. 207-208, Dingle et. al. 1983). These fossiliferous beds were previously prospected for coal. Among the macroplants various ferns, cycads and conifers have been identified, most of which are also known from the Kirkwood beds of the better known Algoa Basin. A rich palynoflora of some 36 taxa, including several fern groups, has been isolated from these beds by Martin (1960).

The fossil record of the Buffelskloof Formation is largely unknown since this unit has only been differentiated from the “true” Enon Formation on more recent geological maps. It is often unclear within which formation of the Uitenhage Group the very sparse fossil record assigned to the “Enon” may in fact occur. Several authors (e.g. Toerien & Hill 1989, Le Roux 2000) refer to records of fossil wood from the Enon Formation, apparently – but mistakenly - based on the early sheet

John E. Almond (2019) 11 Natura Viva cc explanation by Haughton et al. (1937). In some cases this may refer to fossil plant material from the younger (Early Cretaceous) Kirkwood Formation (“Wood Beds”) which is recorded from several localities in the Gamtoos Basin. Rare and fragmentary fossil wood specimens are recorded from conglomeratic facies of the Uitenhage Group in the Algoa Basin (McLachlan & McMillan 1976, Dingle et al. 1983, p. 117 and refs. therein). Fragments of transported wood as well as rolled vertebrate bones and teeth (e.g. of dinosaurs) might occasionally be preserved in the Buffelskloof breccio-conglomerates, especially in association with the finer-grained sandstone interbeds. However, the overall palaeontological sensitivity of the coarser grained facies of the “Enon” sensu lato is clearly low to very low (Almond et al. 2008, Muir et al. 2017a).

 Late Caenozoic alluvium

Late Caenozoic colluvial deposits such as scree, debrites and sheetwash are usually unfossiliferous. Neogene to Recent alluvial deposits may contain sparse to concentrated fossil remains of various types, especially within consolidated or semi-consolidated older sediments, but in mountainous areas they tend to be of low palaeontological sensitivity. In coarse sediments such as conglomerates occasional robust fossils such as rolled bones, teeth and horncores of vertebrates (e.g. mammals) may be found, but these are often highly disarticulated and abraded. However, well-preserved skeletal remains of plants (e.g. wood, roots) and invertebrate animals (e.g. freshwater molluscs and crustaceans, terrestrial gastropods) as well various trace fossils (e.g. calcretised root casts / rhizoliths, termitaria and other burrows) may be preserved within finer- grained alluvium such as silts and sands. Fine-grained vlei (marsh or wetland) deposits such as peats and carbonaceous muds along ancient water courses or associated with springs along fault lines may preserve an important record of subfossil plant material (e.g. reeds, mosses, wood) as well as insects and palynomorphs (fossil spores and pollens). Human artefacts such as stone tools that can be assigned to a specific interval of the archaeological time scale (e.g. Middle Stone Age) can be of value for constraining the age of Pleistocene to Recent drift deposits like alluvial terraces.

5. CONCLUSIONS & RECOMMENDATIONS

Ordovician-aged fluvial bedrocks of the Peninsula Formation (Table Mountain Group) as well as the overlying Late Caenozoic colluvial or alluvial deposits at the preferred Alternative 1 site are all of low palaeontological sensitivity. The bedrocks here lie close to or within the major Baviaanskloof Fault Zone and are probably deformed and brecciated (fractured in situ), further compromising fossil preservation. The impact significance of the proposed Interpretive Centre on fossil heritage resources in the Baviaanskloof WHS is considered to be VERY LOW in the case of the preferred Alternative 1 site.

The highly-disturbed Late Caenozoic alluvium mapped at surface at the Alternative 2 site is likewise of low palaeontological sensitivity. However, satellite images suggest that potentially- fossiliferous Mesozoic sediments of the Uitenhage Group might occur here at depth, close to or beneath the site, since they are well-exposed on the southern flanks of the Baviaanskloof immediately to the south. Potentially-fossiliferous mudrocks of the Late Ordovician Cederberg Formation mapped to the north of the Alternative 2 site are probably mantled by thick superficial deposits (colluvium / alluvium / soils) and so are unlikely to be directly affected by the proposed development (e.g. upgrading of access roads). On a precautionary basis, the impact significance of the proposed Interpretive Centre on fossil heritage resources in the Baviaanskloof WHS in the case of the Alternative 2 site is considered to be MEDIUM. There is a preference on

John E. Almond (2019) 1 2 Natura Viva cc palaeontological heritage grounds for the Alternative 1 site which is already preferred on other grounds. However, the stratigraphy and palaeontological sensitivity of the two site options can only be accurately assessed through fieldwork. Confidence levels for this study are accordingly rated as only MODERATE.

It is recommended that, pending the potential discovery of significant new fossil remains during construction of the Baviaanskloof WHS Interpretive Centre development:

 An exemption from further specialist palaeontological studies and mitigation should be granted if the Alternative 1 site is chosen;  A pre-construction site visit by a suitably qualified palaeontologist should be commissioned by the developer if the Alternative 2 site is chosen. The palaeontologist concerned should record any fossil heritage resources within the development footprint or its vicinity and submit a specialist report to ECPHRA with recommendations for any monitoring or mitigation measured relevant to the construction phase.

6. ACKNOWLEDGEMENTS

Mr Bathini Vanqa of MBSA Consulting, East London, is thanked for commissioning this study as well as for providing background information. I am grateful to Mnr Kobus Reichert of Eastern Cape Heritage Consultants cc, Jeffreys Bay, for helpful discussions regarding this project, for additional project data and to Dr Rob Muir of UCT for kindly sharing recent unpublished data on the Uitenhage Group of the Eastern Cape.

7. REFERENCES

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ALMOND, J.E. 1998a. Trace fossils from the Cape Supergroup (Early Ordovician – Early Carboniferous) of South Africa. Journal of African Earth Sciences 27 (1A): 4-5.

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ALMOND, J.E. 2010a. Palaeontological impact assessment: desktop study. Jeffrey’s Bay Wind Project, Kouga Municipality, Eastern Cape Province, 18 pp. Natura Viva cc, Cape Town.

John E. Almond (2019) 13 Natura Viva cc ALMOND, J.E. 2010b. Wanhoop Borehole Scheme Extension, Eden District Municipality, Western Cape Province. Palaeontological impact assessment: desktop study, 12 pp. Natura Viva cc, Cape Town.

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DE KLERK, W.J. 2008. A review of the occurrence of disarticulated Early Cretaceous sauropod dinosaur fossils from the Kirkwood Formation of the Oudtshoorn and Algoa Basins. Programme and abstracts, Biennial Conference of the Palaeontological Society of South Africa, Matjiesfontein September 2008, 90-91.

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John E. Almond (2019) 14 Natura Viva cc DU PREEZ, J.W. 1944. Lithology, structure and mode of deposition of the Cretaceous deposits in the Oudtshoorn area. Annals of the University of Stellenbosch 22(A): 209-237, pls. 1-12.

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LE ROUX, F.G. 2000. The geology of the Port Elizabeth – Uitenhage area. Explanation to 1: 50 000 geology sheets 3325 DC & DD, 3425 BA Port Elizabeth, 3325 CD and 3425 AB Uitenhage, 3325 CB Uitenhage Noord and 3325 DA Addo, 55 pp. Council for Geoscience, Pretoria.

LOCK, B.E., SHONE, R., COATES, A.T. & HATTON, C.J. 1975. Mesozoic Newark-type sedimentary basins within the Cape fold belt of southern Africa. 9th International Sedimentological Congress, Nice 4: 217-226.

MACRAE, C. 1999. Life etched in stone. Fossils of South Africa. 305pp. The Geological Society of South Africa, Johannesburg.

MALAN, J.A. & THERON, J.N. 1989. Nardouw Subgroup. Catalogue of South African lithostratigraphic units, 2 pp. Council for Geoscience, Pretoria.

MALAN, J.A., THERON, J.N. & HILL, R.S. 1989. Lithostratigraphy of the Goudini Formation (Table Mountain Group). South African Committee for Stratigraphy, Lithostratigraphic Series No. 2, 5pp.

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John E. Almond (2019) 16 Natura Viva cc SHONE, R.W. 1986. Field guide to an outcrop of Enon Conglomerate near Andrieskraal, Mesozoic Gamtoos Basin. In Sedplett ’86. Excursion guidebook 21c. Geocongress ’86. Geological Society of South Africa, 38-44.

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8. QUALIFICATIONS & EXPERIENCE OF THE AUTHOR

Dr John Almond has an Honours Degree in Natural Sciences (Zoology) as well as a PhD in Palaeontology from the University of Cambridge, UK. He has been awarded post-doctoral research fellowships at Cambridge University and in Germany, and has carried out palaeontological research in Europe, North America, the Middle East as well as North and South Africa. For eight years he was a scientific officer (palaeontologist) for the Geological Survey / Council for Geoscience in the RSA. His current palaeontological research focuses on fossil record of the Precambrian - Cambrian boundary and the Cape Supergroup of South Africa. He has recently written palaeontological reviews for several 1: 250 000 geological maps published by the Council for Geoscience and has contributed educational material on fossils and evolution for new school textbooks in the RSA.

Since 2002 Dr Almond has also carried out palaeontological impact assessments for developments and conservation areas in the Western, Eastern and Northern Cape, Limpopo, Mpumalanga, Northwest, Free State, KwaZulu-Natal and Gauteng Provinces under the aegis of his Cape Town- based company Natura Viva cc. He has served as a long-standing member of the Archaeology, Palaeontology and Meteorites Committee for Heritage Western Cape (HWC) and an advisor on palaeontological conservation and management issues for the Palaeontological Society of South Africa (PSSA), HWC and SAHRA. He is currently compiling technical reports on the provincial palaeontological heritage of Western, Northern and Eastern Cape for SAHRA and HWC. Dr

John E. Almond (2019) 17 Natura Viva cc Almond is an accredited member of PSSA and APHP (Association of Professional Heritage Practitioners – Western Cape).

Declaration of Independence

I, John E. Almond, declare that I am an independent consultant and have no business, financial, personal or other interest in the proposed project, application or appeal in respect of which I was appointed other than fair remuneration for work performed in connection with the activity, application or appeal. There are no circumstances that compromise the objectivity of my performing such work.

Dr John E. Almond Palaeontologist Natura Viva cc

John E. Almond (2019) 18 Natura Viva cc APPENDIX 1: CHANCE FOSSIL FINDS PROCEDURE: Baviaanskoof World Heritage Site Interpretive Centre on Farm Nieuwe Kloof 202

Province & region: EASTERN CAPE, Willlowmore District Responsible Heritage ECPHRA (Contact details: Mr Sello Mokhanya, 74 Alexander Road, King Williams Town 5600; Resources Agency [email protected]) Table Mountain Group (Peninsula Formation), Uitenhage Group (possibly Kirkwood / Buffelskloof Formation); Late Rock unit(s) Caenozoic alluvium Trace fossils in Peninsula Fm. Possible petrified wood, dinosaur bones, plant compressions, charcoal in Uitenhage Potential fossils Group beds. Reworked mammalian teeth / bones / horncores, non-marine molluscs and trace fossils in overlying Caenozoic alluvium. 1. Once alerted to fossil occurrence(s): alert site foreman, stop work in area immediately (N.B. safety first!), safeguard site with security tape / fence / sand bags if necessary. 2. Record key data while fossil remains are still in situ:  Accurate geographic location – describe and mark on site map / 1: 50 000 map / satellite image / aerial photo  Context – describe position of fossils within stratigraphy (rock layering), depth below surface  Photograph fossil(s) in situ with scale, from different angles, including images showing context (e.g. rock layering) 3. If feasible to leave fossils in situ: 3. If not feasible to leave fossils in situ (emergency procedure only):  Alert Heritage Resources Agency and project  Carefully remove fossils, as far as possible still enclosed within the palaeontologist (if any) who original sedimentary matrix (e.g. entire block of fossiliferous rock) ECO protocol will advise on any  Photograph fossils against a plain, level background, with scale necessary mitigation  Carefully wrap fossils in several layers of newspaper / tissue paper /  Ensure fossil site remains plastic bags safeguarded until clearance  Safeguard fossils together with locality and collection data (including is given by the Heritage collector and date) in a box in a safe place for examination by a Resources Agency for work palaeontologist to resume  Alert Heritage Resources Agency and project palaeontologist (if any) who will advise on any necessary mitigation 4. If required by Heritage Resources Agency, ensure that a suitably-qualified specialist palaeontologist is appointed as soon as possible by the developer. 5. Implement any further mitigation measures proposed by the palaeontologist and Heritage Resources Agency Record, describe and judiciously sample fossil remains together with relevant contextual data (stratigraphy / sedimentology / taphonomy). Ensure that fossils are curated in an approved repository (e.g. museum / university / Specialist Council for Geoscience collection) together with full collection data. Submit Palaeontological Mitigation report to Heritage palaeontologist Resources Agency. Adhere to best international practice for palaeontological fieldwork and Heritage Resources Agency minimum standards.

John E. Almond (2019) 19 Natura Viva cc