Western Allen Ridge Gold Mine (Pty) Ltd Gas Exploration Right Application near Kroonstad in the Free State Province

Heritage Scoping Report

Prepared for: Project Number: Shango Solutions (Pty) Ltd SHA6192

March 2020

Turnberry Office Park, Phone: +27 (0) 11 789 9495 Digby Wells and Associates Directors: J Leaver (Chairman)*, Digby Wells House. Fax: +27 (0) 11 789 9495 (South Africa) (Pty) Ltd NA Mehlomakulu*, DJ Otto, M Rafundisani 48 Grosvenor Road, E-mail: [email protected] Company Registration: 2010/008577/07 *Non-Executive Bryanston,2191 Website: www.digbywells.com

This document has been prepared by Digby Wells Environmental.

Report Type: Heritage Scoping Report

Western Allen Ridge Gold Mine (Pty) Ltd Gas Exploration Right Project Name: Application near Kroonstad in the Free State Province

Project Code: SHA6192

Name Responsibility Signature Date

Shannon Hardwick

HRM Consultant Report Compilation March 2020 ASAPA Member: 451

Justin du Piesanie

Divisional Manager: Social Technical Review March 2020 and Heritage Services

ASAPA Member 270

This report is provided solely for the purposes set out in it and may not, in whole or in part, be used for any other purpose without Digby Wells Environmental prior written consent.

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Heritage Scoping Report Western Allen Ridge Gold Mine (Pty) Ltd Gas Exploration Right Application near Kroonstad in the Free State Province SHA6192

EXECUTIVE SUMMARY

Western Allen Ridge Gold Mine (Pty) Ltd (hereinafter Western Allen Ridge), a subsidiary of White Rivers Exploration (WRE), has been granted a Technical Cooperation Permit (TCP1) for a target area approximately 15 km east of Kroonstad in the Free State Province. Western Allen Ridge intends to apply for an Exploration Right over the TCP area (“the Project”). Western Allen Ridge proposes to apply for an Exploration Right for the entire TCP area for three years. Western Allen Ridge aims to drill and establish two gas exploration wells in the second year of the permit term and, based on the outcomes of these wells, will establish an additional two wells in the third year. Western Allen Ridge will need to construct access roads to these wells. Shango Solutions (hereinafter Shango) are the geological consultants for WRE and Western Allen Ridge and are undertaking the Environmental Impact Assessment (EIA) process in support of the Exploration Right Application in compliance with application national legislation. Shango appointed Digby Wells Environmental (hereinafter Digby Wells) to undertake a Heritage Resources Management (HRM) process in support of the EIA process in compliance with the National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA). This report constitutes the Heritage Scoping Report (HSR), the second deliverable in the HRM process, for submission to the Heritage Resources Authorities (HRAs). The cultural landscape of the regional study area predominantly comprises the historical built environment and archaeological artefacts representing the Middle Stone Age (MSA). This notwithstanding, archaeological artefacts representing the Later Stone Age (LSA) and Late Farming Community (LFC) periods as well as burial grounds and graves have been recorded. These resources may, to lesser or greater extent, be directly, indirectly or cumulatively impacted on by development activities. The table below presents an overview of the anticipated impacts to heritage resources by the Project.

1 Granted 09 May 2019, Petroleum Agency of South Africa (PASA) Reference Number: 12/2/167 TCP.

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Potential heritage Resources and Risks

Heritage Risks Consequence of Identification

Digby Wells will assess the impact to these Impact to fossil-bearing material. identified heritage resources, where such resources may be present in the Project area. This assessment will be based on the Impact to in situ archaeological material. proposed infrastructure layout design and will be informed by the Cultural Significance (CS) of the heritage resources. Impact to in situ historical built environment sites. Western Allen Ridge may need to implement mitigation measures in compliance with Impact to in situ burial grounds or graves. Sections 34, 35 and/or 36 of the NHRA, as may be applicable.

Based on the Project description, Digby Wells is of the opinion that there is potential to alter the current status quo of heritage resources identified within the Project area. The potential impacts posed by Project activities to the heritage resources require an assessment to provide reasonable and feasible mitigation and management measures aimed at removing or reducing the intensity of the potential impacts. Digby Wells will undertake a Heritage Impact Assessment (HIA) process to assess the impacts to cultural heritage resources and a desktop specialist Palaeontology Impact Assessment (PIA) process to consider impacts to the fossil heritage resources.

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Heritage Scoping Report Western Allen Ridge Gold Mine (Pty) Ltd Gas Exploration Right Application near Kroonstad in the Free State Province SHA6192

TABLE OF CONTENTS

1 Introduction ...... 1

1.1 Project Background and Description...... 1 1.2 Project Alternatives ...... 4 1.3 Terms of Reference ...... 4 1.4 Scope of Work ...... 4 1.5 Expertise of the Specialists ...... 4 1.6 Structure of the Report ...... 4 2 Methodology...... 5

2.1 Defining the Study Area ...... 5 2.2 Secondary Data Collection ...... 6 3 Cultural Heritage Baseline Description ...... 7

3.1 Geological Setting and Palaeontological Setting ...... 10 3.2 Archaeo-historical context ...... 13 4 Potential Heritage Risks ...... 16

5 Predicted Heritage Impacts ...... 17

6 Scoping Assessment...... 19

7 Proposed Way Forward ...... 21

8 Conclusion ...... 21

9 Works Cited ...... 22

LIST OF FIGURES

Figure 3-1: Heritage Resources Identified Within the Regional Study Area ...... 8 Figure 3-2: Location and Envisaged Plate Tectonic Setting of the Main Karoo Basin during the Late Triassic ...... 11

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LIST OF TABLES

Table 4-1: Secondary Data Sources ...... 6 Table 5-1: Periods in the South African past ...... 7 Table 3-2: Lithostratigraphic Units underlying the Regional Study Area and Associated Palaeosensitivity ...... 12 Table 5-2: Stonewalled Settlement Types ...... 14 Table 7-1: Identified Heritage Risks That May Arise for Western Allen Ridge ...... 17 Table 7-2: Potential heritage Resources and Risks ...... 17 Table 5-1: Predicted Heritage Impacts ...... 18 Table 9-1: Scoping assessment ...... 20

LIST OF PLANS

Plan 1: Regional Setting ...... 2 Plan 2: Proposed Infrastructure Layout ...... 3 Plan 3: Previously-identified Heritage Resources within the Regional Study Area ...... 9

LIST OF APPENDICES

Appendix A: Specialist CVs Appendix B: HRM Methodology

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Heritage Scoping Report Western Allen Ridge Gold Mine (Pty) Ltd Gas Exploration Right Application near Kroonstad in the Free State Province SHA6192

1 Introduction Western Allen Ridge Gold Mine (Pty) Ltd (hereinafter Western Allen Ridge), a subsidiary of White Rivers Exploration (WRE), has been granted a Technical Cooperation Permit (TCP2) for a target area approximately 15 km east of Kroonstad in the Free State Province. Western Allen Ridge intends to apply for an Exploration Right over the TCP area (“the Project”). Shango Solutions (hereinafter Shango) are the geological consultants for WRE and Western Allen Ridge presently undertaking the Environmental Impact Assessment (EIA) process in support of the Exploration Right Application in terms of Section 79 of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002) (MPRDA). The EIA process is being undertaken in compliance with: ● The National Environmental Management Act, 1998 (Act No. 107 of 1999) (NEMA); and ● The EIA Regulations, 2014 (Government Notice Regulation [GN R] 982 of 4 December 2014, as amended) (EIA Regulations, 2014, as amended) promulgated under the NEMA.

Shango appointed Digby Wells Environmental (hereinafter Digby Wells) to undertake a Heritage Resources Management (HRM) process in support of the EIA process in compliance with the National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA). This report constitutes the Heritage Scoping Report (HSR), the second deliverable in the HRM process, for submission to the South African Heritage Resources Agency (SAHRA) and Heritage Free State (HFS).

1.1 Project Background and Description Western Allen Ridge holds the TCP over an area of 33 605.29 hectares approximately 15 km east of Kroonstad. WRE has investigated the Kroonstad area for gold and gas in the past and has held a TCP and a prospecting right over the Project area. Plan 1 presents the regional setting within which the Project is located. Western Allen Ridge intends to apply for an Exploration Right for the entire TCP area for three years. During the second year of the permit application period, Western Allen intends to drill and establish two gas exploration wells. Based on the outcomes of the results from the exploration wells, Western Allen Ridge may drill and establish an additional two exploration wells. Plan 2 presents the proposed location of these exploration wells.

2 Granted 09 May 2019, Petroleum Agency of South Africa (PASA) Reference Number: 12/2/167 TCP.

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1.2 Project Alternatives Western Allen Ridge will base the activities in the third year of the application on the outcomes of the first two exploration wells. At this stage, no other alternatives have been considered in the Mine Works Programme (MWP). An alternative that could be considered at this stage is the “no-go” alternative. Should the Project not obtain approval, or not go ahead for any reason, the potential environmental impacts associated with the development of the mine as described in Section 1.1 would not occur. However, the potential benefits associated with the Project would also not occur. These potential benefits will be explored in the Heritage Impact Assessment (HIA) report.

1.3 Terms of Reference Shango appointed Digby Wells to undertake the specialist HRM process in accordance with the national regulatory framework, with specific reference to Section 38 of the NHRA.

1.4 Scope of Work The Scope of Work (SoW) for the specialist HRM process included the compilation of an HSR to comply, in part, with the requirements of Section 38(3) of the NHRA. Digby Wells completed the following activities as part of this SoW:

● Describing the predominant cultural landscape, supported through secondary data collection;

● Identifying the potential impacts to heritage resources, based on Project-related activities and sources of risk to the heritage resources or the Project; and

● Recommending the specific Terms of Reference (ToR) for the pending HIA.

1.5 Expertise of the Specialists Appendix A includes the CVs of the specialists involved in the HRM process.

1.6 Structure of the Report This document constitutes a description of the proposed Project, a summary of the cultural heritage landscape within which the Project is situated, a brief methodology relevant to the activities undertaken to compile this report and a description of the risks and impacts foreseen should the Project go ahead. The risks and impacts will be assessed in more detail in the HIA report. The HIA report will include a description of the legislation and policies applicable to the HRM process as well as a description of the constraints and limitations experienced in the HRM process. The HIA report will include a detailed table indicating compliance of the HRM process with Appendix 6 of Government Notice Regulation (GN R) 326 of 07 April 2017.

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Heritage Scoping Report Western Allen Ridge Gold Mine (Pty) Ltd Gas Exploration Right Application near Kroonstad in the Free State Province SHA6192

2 Methodology The following section presents a summary of the methods employed in the compilation of this report. A more detailed methodology statement is included in Appendix B. Methodologies that will be used for the HIA process will be described in the HIA.

2.1 Defining the Study Area Heritage resources do not exist in isolation to the greater natural and social, including the socio-cultural, socio-economic and socio-political, environments. In addition, the NHRA requires the grading of heritage resources in terms of national, provincial and local concern based on their importance and the resultant official (i.e. State) management effort required. The type and level of baseline information necessary to adequately predict heritage impacts varies between these categories. Considering these requirements, Digby Wells defined four nested study areas for the purposes of study. These include:

● The infrastructure area: the farm portions associated with the proposed gas exploration wells and infrastructure design associated with the Project, including a 500 m buffer area. In some cases, the proposed infrastructure may extend linearly, in which case the infrastructure area will include the linear infrastructure as well as a 200 m buffer on either side of the infrastructure footprint;

● The Project area or site-specific study area: the farm portions included in the TCP area and which will constitute the proposed Prospecting Right;

● The local study area: the area most likely to be influenced by any changes to heritage resources in the Project area or where Project development could cause heritage impacts. Defined as the area bounded by the local municipality, in this instance the Moqhaka Local Municipality (MLM) and the Ngwathe Local Municipality (NLM), with particular reference to the immediate surrounding properties and/or farms. The local study area was specifically examined to offer a backdrop to the socio-economic conditions within which the proposed development will occur. The local study area furthermore provided the local development and planning context that may contribute to cumulative impacts; and

● The regional study area: the area bounded by the district municipality, which here is the Fezile Dabi District Municipality (FDDM). Where necessary, the regional study area may be extended outside the boundaries of the district municipality to include much wider regional expressions of specific types of heritage resources and historical events. The regional study area also provided the regional development and planning context that may contribute to cumulative impacts.

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2.2 Secondary Data Collection Data collection assists in the development of a cultural heritage baseline profile of the study area under consideration. Qualitative data was collected through secondary information sources, i.e. desktop literature review, to inform this HSR. A survey of diverse information repositories was made to identify appropriate relevant information sources. These sources were analysed for credibility and relevance. These credible, relevant sources were then critically reviewed. The objectives of the literature review include:

● Gaining an understanding of the cultural landscape within which the proposed Project is located; and

● Identify any potential fatal flaws, sensitive areas, current social complexities and issues and known or possible tangible heritage.

Repositories that were surveyed included the South African Heritage Resources Information System (SAHRIS), online/electronic journals and platforms and select internet sources. This HSR includes a summary and discussion of the most relevant findings. Table 2-1 lists the sources consulted in the literature review (refer to Section 9 for more detailed references). Table 2-1: Secondary Data Sources

Reviewed Secondary Data

Databases

University of the Witwatersrand (Wits) database Genealogical Society of South Africa (2011) (2010)

SAHRIS Database SAHRIS Palaeo-Sensitivity Map (SAHRA, 2017)

SAHRIS Cases

Map ID: 01496 Map ID:01767 Case ID: 12862 Map ID: 01566 Case ID: 13515 Case ID: 4117 Map ID: 01540 Case ID: 11817 Case ID: 2256 Map ID: 02388 Case ID: 3169 Case ID: 3332 Map ID: 01608 Case ID: 5659 Case ID: 9304 Map ID: 01522 Case ID: 13583 Case ID: 3420 Map ID: 01812 Case ID: 5818 Case ID: 4560 Map ID: 01790 Case ID: 12861 Case ID: 13222

Cited Text

Behrens & Swanepoel, 2008 Clark, 1982 Deacon & Deacon, 1999

Daniels, 2013 Daniels & Tomsana, 2014 Delius & Cope, 2007

Delius, et al., 2014 De Bruyn & Tomose, 2018 De Bruyn & Mosweu, 2019

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Heritage Scoping Report Western Allen Ridge Gold Mine (Pty) Ltd Gas Exploration Right Application near Kroonstad in the Free State Province SHA6192

Reviewed Secondary Data

Dreyer, 2005, 2006a, 2006b, Esterhuysen & Smith, 2007 Fairbridge, 1918 2006c, 2007, 2008

Groenwald & Groenewald, Huffman, 2007 Johnson, et al., 2006 2014

Kruger, 2018 Landau, 2010 Maggs, 1976

Mitchell, 2002 Pistorius, 2004 Sebogodi, 2014

Swanepoel, et al., 2008 Van Der Walt, 2013a, 2013b

3 Cultural Heritage Baseline Description This section defines the cultural landscape through providing a brief description that offers the reader contextual information, as well as assists the identification of potential risks and impacts to the heritage resources. The cultural heritage baseline description considered the predominant landscape based on the identified heritage resources within the regional and local study area. Table 3-1 presents the broad timeframes for the major periods of the past in South Africa. Table 3-1: Periods in the South African past

2 million years ago (mya) to 250 Early Stone Age (ESA) thousand years ago (kya) The Stone Age Middle Stone Age (MSA) 250 kya to 20 kya

Later Stone Age (LSA) 20 kya to 500 CE (Common Era3)

Farming Early Farming communities (EFC) 500 to 1400 CE Communities Late Farming Communities (LFC) 1100 to 1800 CE

1500 CE to 1994 Historical Period - (Behrens & Swanepoel, 2008)

Adapted from Esterhuysen & Smith (2007) Figure 3-1 below presents the results of the review of previously-completed heritage assessments. In total, 28 heritage resources were identified within the regional, local and site- specific study areas. Plan 3 shows where such heritage resources have been recorded. The predominant tangible heritage resources recorded in the area under consideration demonstrate affiliations with the historical period, dominated by burial grounds and graves and

3 Common Era (CE) refers to the same period as Anno Domini (“In the year of our Lord”, referred to as AD): i.e. the time after the accepted year of the birth of Jesus Christ and which forms the basis of the Julian and Gregorian calendars. Years before this time are referred to as ‘Before Christ’ (BC) or, here, BCE (Before Common Era).

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the historical built environment. This notwithstanding, archaeological resources representing the Stone Age and LFC have been recorded in the greater study area.

42.9%

32.1% Archaeological - Indeterminate 21.4% Stone Age Archaeological - LFC

Burial Grounds & Graves 3.6% Historical Built Environment

Figure 3-1: Heritage Resources Identified Within the Regional Study Area

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3.1 Geological Setting and Palaeontological Setting The geological context and palaeontological sensitivities of the Project area will be described in more detail in a specialist Palaeontological Impact Assessment (PIA) report which will be appended to the HIA report. This section presents a broad overview of the regional geological setting and the palaeontological sensitivities which may be expected within the Project area. The regional study area is underlain predominately by lithologies associated with the Karoo Supergroup and forms part of the Main Karoo Basin. The Main Karoo Basin dates from the Late Carboniferous to the Middle Jurassic periods, which is approximately 320 to 145 mya (Johnson, et al., 2006). The Main Karoo Basin constitutes a retro-arc foreland basin. As described by Johnson et al (2006), this is because of:

● The thick flysch-molasse succession which wedges out northwards over the adjacent craton;

● Its position behind an inferred magmatic arc; and

● The associated fold thrust belt produced by northward subduction of oceanic lithosphere located south of the arc.

These processes allowed for sedimentation of the basin, forming what is collectively known as the Karoo Supergroup (Johnson, et al., 2006). These sediments cover approximately 700 000 km2, including the site-specific study area. Figure 3-2 illustrates the extent of the Main Karoo Basin and the envisaged plate tectonic setting of the basin in the Late Triassic. Within the Karoo Basin, two geological features are relevant to the Project: the Volksrust Formation of the Ecca Group and the Adelaide Sub-group. Table 3-2 presents the geological sequence of these features. The Ecca Group is the most palaeontologically sensitive of the layers within the Karoo Supergroup (labelled E in Figure 3-2) and the group is considered of very high palaeosensitivity, although the sensitivity of various layers may differ (Groenwald & Groenewald, 2014). Ecca Group sediments are well-known for their wealth of plant fossils, characterised by assemblages of Glossopteris (plant species defined by through their fossil leaves). These layers also include significant coal reserves. In the north-eastern parts of the Free State Province, the Ecca Group consists of the lower Pietermaritzburg Formation, the Vryheid Formation and the upper Volksrust Formation (Groenwald & Groenewald, 2014). The Project area is underlain by the Volksrust Formation. This consists of monotonous sequences of grey shale. Fossils are significant but are rarely recorded. Table 3-2 includes the types of fossils found within the Formation. Overlying the Ecca group is the late Permian to early Triassic Beaufort Group of sediments (Groenwald & Groenewald, 2014). These sediments are divided into two sub-groups – a lower Adelaide Sub-group and an upper Tarkastad Sub-group. The Adelaide Sub-group is comprised of sediments deposited in a range of environments, from deltaic environments in the lower part of the sub-group to lacustrine and playa lake environments in the upper part of the sub-group. Table 3-2 presents the types of fossils expected within the sub-group.

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Figure 3-2: Location and Envisaged Plate Tectonic Setting of the Main Karoo Basin during the Late Triassic

Adapted from Johnson, et al. (2006)

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Table 3-2: Lithostratigraphic Units underlying the Regional Study Area and Associated Palaeosensitivity

Eo Lithographic Units Era Period Ma Sub- Significance Fossils n Supergroup Group Formation

group

145 Diverse terrestrial and freshwater tetrapods from the Pristeognathus to Koonop Formation

Dicynodon Assemblage Zones Triassic Mesozoic (amphibians, true reptiles and

synapsids) and Lystrosaurus

Middelton Formation Assemblage Zone (dicynodonts, group - cynodonts, therocephalians, Very High procolophonids and archosaurs), palaeoniscoid fish, freshwater bi valves,

trace fossils (including tetrapod BeaufortGroup

AdelaideSub trackways, vertebrate burrows and

Balfour Formation coprolites), and insects. These

formations may also include vascular Phanerozoic

plants (Glossopteris flora) and petrified KarooSupergroup

Permian wood. Palaeozoic Trace fossils, rare temnospondyl

amphibian remains, invertebrates (bivalves, insects), minor coals with Volksrust Formation Moderate plant remains, petrified wood, organic microfossils (acritarchs), low-diversity

EccaGroup marine to non-marine trace fossil assemblages. 300 Adapted from Groenwald & Groenewald (2014)

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3.2 Archaeo-historical context The Stone Age in southern Africa comprises three broad phases, which are described according to the lithic tools and material culture produced by the various hominid species through time. These phases are:

● The ESA;

● The MSA; and

● The LSA.

The survey of the heritage assessments previously completed within the regional study area yielded one expression of the indeterminate Stone Age (accounting for 3.6% of the identified records). The resource comprised of a low-density scatter of stone tools (Pistorius, 2004). Material associated with the MSA and LSA has been recorded within the province and may potentially be uncovered during Project activities. As such, a brief description of the periods within the Stone Age follows. The ESA is comprised predominantly of large handaxes and cleavers made of coarse-grained materials (Esterhuysen & Smith, 2007). This period occurred between 2 mya and 250 kya and is associated with Australopithecus and early Homo hominid species. The MSA dates from approximately 300 kya to 20 kya. High proportions of minimally modified blades, created using the Levallois technique, characterise the early MSA lithic industries (Clark, 1982; Deacon & Deacon, 1999). The MSA can be more broadly defined through the presence of blades and points produced on good-quality raw material. The presence of bone tools, ochre, beads and pendants also define this period. The LSA dates between 40 kya to the historical period. LSA lithics are specialised where specific tools have been created for specific tasks (Mitchell, 2002). LSA assemblages can also include bone points and commonly include diagnostic tools such as microlithic scrapers and segments. In southern Africa, the LSA is closely associated with hunter-gatherer groups, such as the San. Regional hunter-gatherer occupation is well documented, although open sites are usually poorly preserved and difficult to identify because of the nomadic nature of these peoples. The LSA is further defined by evidence of ritual practise and complex societies (Deacon & Deacon, 1999). This is often expressed through rock art. The literature survey did not yield any records of rock art within the regional study area. The San were later followed by the various peoples of the Farming Community. The farming community period correlates to the movements of Bantu-speaking agro-pastoralists moving into southern Africa and is divided into two stages to distinguish between widespread events: the EFC and the LFC. No EFC material was recorded in the reviewed literature.

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LFC sites can be identified through secondary tangible surface indicators, such as ceramics and evidence for domesticated animals, i.e. dung deposits or faunal remains. These resources provide motivation for settlement and possible trade networks and are distributed across the region (Huffman, 2007; Delius, et al., 2014). The Makgwareng facies of ceramics occurs within the regional study area. These ceramics are characterised by decorations including appliqué, finely-stamped triangles and rim notching (Huffman, 2007). These ceramics date from 1700 to 1820 CE. Stonewalling is the most visible indicator of LFC settlements. Table 3-3 presents a summary of the stonewalled settlement types within the province. Within the regional study area, Type V is the dominant stonewalling type. First described by Maggs (1976), these settlements consist of a ring around which primary enclosures are grouped. The closures are either contiguous or linked by secondary walling to form a secondary enclosure. There may be additional free- standing structures around the periphery of the settlement unit, but there is no surrounding wall. Makgwareng ceramics are typically associated with Type V walling. Within the regional study area, the LFC accounts for nine records or 21.4% of the identified heritage resources included in the literature survey. These resources include stonewalling, low density artefact scatters and sites which include stonewalling and material culture including potsherds and metal fragments (Dreyer, 2005; 2006a; 2006b; WITS, 2010). Table 3-3: Stonewalled Settlement Types

Central Cattle Pattern

Moor Park Cluster Ntsuanatsatsi Cluster

Type N 15th-17th Century

Moor Park 14th-16th Century Badfontein 16th Century

Doornspruit 19th Century

Klipriviersberg 19th Century

Melora 16th Century – [unknown] Type V 19th Century

Molokwane 19th Century

Type Z 19th Century

Kwamaza 18th Century – Historic Type B 19th Century

Tukela 19th Century

Adapted from Huffman (2007) The historical period4 is commonly regarded as the period characterised by contact between Europeans and Bantu-speaking African groups and the written records associated with this

4 In southern Africa, especially in Mpumalanga, the last 500 years represents a formative period that is marked by enormous internal economic invention and political experimentation that shaped the cultural contours and categories of modern identities outside of European contact. This period is currently not well documented but is being explored through the ‘500 Year Initiative’ (Swanepoel, et al., 2008).

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interaction. However, the division between the LFC and historical period is artificial, as there is a large amount of overlap between the two. An example of the overlap between the LFC and the historical period is the Mfecane or, north of the Orange River, the Difaqane. These terms refer to a period of violence and unrest between approximately 1817 to 1826 AD (Landau, 2010). The understanding of the period is that Mzilikazi and his Ndebele group were pushed out of their territory by the Zulu group led by Shaka. This displacement had a knock-on effect, as multiple groups were subsequently displaced to the north and the west. A drought during this time exacerbated the instability and increased the pressure on food supplies, which were already running low. European settlers, traders, missionaries and travellers moving into the interior further added to instability and resulting power struggles. The Mfecane/Difaqane was characterised by unprecedented (at least within the records of the Europeans travelling within southern Africa) social and political mobilisation and violence across the Highveld as individuals sought personal and food security. As a result of social and political upheaval, the Highveld was vulnerable to intrusive groups including the Swazi and the Voortrekkers. Groups of Afrikaaners initiated a move from the Cape to the interior to establish an independent state in approximately 1835, in reaction to increased British liberalism and the abolishment of slavery and pass laws. The migration of these Voortrekkers is commonly referred to as the Great Trek (or Groot Trek) and it started with the Robert Schoon Party in 1836. By 1838, the Voortrekkers had settled on both sides of the Vaal River and declared the area Boer lands (Delius & Cope, 2007). Chief Moshoeshoe resisted the influx of the Voortrekkers and sought the assistance of the British Kingdom, sanctioned through the signing of a treaty in 1843. In response, the British, under the Governor of the Cape, issued a proclamation declaring British sovereignty over all the lands between the Orange and Vaal Rivers (Fairbridge, 1918). This proclamation was superseded by the signing of the Sand River Convention in 1852. The Sand River Convention was an agreement between the British and the Voortrekkers to the north of the Vaal acknowledging their independence and the establishment of the Zuid-Afrikaansche Republiek (ZAR). ZAR independence allowed for land to be distributed to its citizens, though the demarcation of farms and the issuing of title deeds. It was not until 17 February 1854 that the independence of the Orange River Sovereignty was recognised, and officially became the Orange Free State with the signing of the Orange River Convention. Subsequent to this, a breach of the agreements by the British resulted in the relationships with the Boers to break down and the start of the Anglo Boer Wars. The South African War of 1899- 1902 (previously referred to as the Second Anglo-Boer War) officially started on October 9th, 1899. The war was the result of building tensions and conflicting political agendas between the Trekboers and the British. The concentration camps associated with the South African War within the Free State province include:

● Kroonstad (approximately 17 km west of the Project area);

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● Heilbron (40 km northeast);

● Vredefortweg (the concentration camp cemetery is located approximately 40 km north of the Project area, as the crow flies);

● Reitz (80 km east);

● Winburg (100 km south);

● Brandfort (150 km southwest);

● Harrismith (160 km southeast);

● Ladybrand (170 km south);

● Bloemfontein (200 km southwest);

● Edenburg (280 km southwest);

● Springfontein (330 km southwest); and

● Bethulie (350 km southwest).

Within the regional study area, historical resources are represented as:

● Built environment resources, including buildings, structural remains and industrial and functional structures (Pistorius, 2004; WITS, 2010; Daniels, 2013; Van Der Walt, 2013b; Daniels & Tomsana, 2014; De Bruyn & Tomose, 2018);

● A low-density scatter of historical artefacts including pottery and a smoking pipe (WITS, 2010); and

● Burial grounds and graves, ranging from burial grounds of less than ten graves to burial grounds of less than 50 graves and including burial grounds of indeterminate size (Pistorius, 2004; Dreyer, 2006c; 2007; 2008; WITS, 2010; Daniels, 2013; Van Der Walt, 2013a; 2013b; Sebogodi, 2014; De Bruyn & Tomose, 2018).

4 Potential Heritage Risks This section considers the potential risks to protected heritage resources as well as the potential risks that could arise for Western Allen Ridge in terms of implementation of the Project. These two aspects are discussed separately. Where Western Allen Ridge knowingly do not take proactive management measures against potential impacts discussed below and in the HIA report, risks arising from the heritage resources may manifest as:

● Litigation in respect of Section 51 of the NHRA;

● Social repercussions; and

● Reputational risk.

Table 4-1 summarises the potential risks that may arise for Western Allen Ridge.

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Table 4-1: Identified Heritage Risks That May Arise for Western Allen Ridge

Description Primary Risk

Heritage resources with a high CS rating are inherently Negative Record of Decision (RoD) sensitive to any development in so far that the continued and/or development restrictions survival of the resource could be threatened. In addition to issued by HFS and/or SAHRA in this, certain heritage resources are formally protected thereby terms of Section 38(8) of the NHRA. restricting various development activities.

Fines Impacting on heritage resources formally and generally Penalties protected by the NHRA without following due process. Seizure of Equipment Due process may include social consultations and/or permit Compulsory Repair / Cease Work application processes to SAHRA and/or HFS. Orders Imprisonment

Where heritage resources are identified during the assessment phase of the HRM process, the risks to such resources must be assessed. Table 4-2 provides an overview of these risks. This will be assessed in more detail during the assessment phase. Table 4-2: Potential heritage Resources and Risks

Heritage Risks Consequence of Identification

Digby Wells will assess the impact to these Impact to fossil-bearing material. identified heritage resources, where such resources may be present in the Project area. This assessment will be based on the Impact to in situ archaeological material. proposed infrastructure layout design and will be informed by the Cultural Significance (CS) of the heritage resources. Impact to in situ historical built environment sites. Western Allen Ridge may need to implement mitigation measures in compliance with Impact to in situ burial grounds or graves. Sections 34, 35 and/or 36 of the NHRA, as may be applicable.

5 Predicted Heritage Impacts Predicted heritage impacts are predominantly associated with Project-related activities and the assessment of impacts is therefore based on the Project description presented in Section 1.1 above. Table 5-1 presents a high-level overview of the predicted impacts to heritage resources. These impacts will be assessed in more detail in the HIA and PIA reports.

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Table 5-1: Predicted Heritage Impacts

Activities Potential impacts Mitigation type Potential for residual risk

Surface or vegetation Potential exposure of previously- clearing ahead of Damage to or destruction of heritage Proactive – amend Project design unidentified heritage resources. There is a construction resources generally protected under where necessary to avoid negative risk that such heritage resources may be Sections 34, 35 and 36 of the NHRA (i.e. Construction of access impacts. damaged or destroyed when exposed. historical structures, archaeological and roads Reactive – mitigate impact, where Negative RoD and/or development fossiliferous material or burial grounds avoidance is not possible. restrictions issued by SAHRA and/or HFS Establishing gas and graves respectively) in terms of Section 38(8) of the NHRA. exploration wells

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6 Scoping Assessment The cultural landscape of the regional study area predominantly comprises the historical built environment and archaeological artefacts representing the MSA. This notwithstanding, archaeological artefacts representing the LSA and LFC as well as burial grounds and graves have been recorded. These resources may, to lesser or greater extent, be directly, indirectly or cumulatively impacted on by development activities. A preliminary scoping assessment of the potential impacts to heritage resources as described in Table 4-2 is presented in Table 6-1. Digby Wells will assess the impacts to the cultural heritage landscape in further detail in the impact assessment phase. Section 8 includes a description of the recommended way forward.

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Table 6-1: Scoping assessment

Probability of impacts

(0 - zero / negligible, 1 - low, 2 likely, 3 - certain)

Specific activity Risk

27)

(S. (S. 28) (S. 28) (S. 31) (S. 32) (S. 34) (S. 35) (S. 35) (S. 35) (S. 36) (S. 37)

Public

National /

Provincial

protection

Structures Meteorites memorials

andgraves

Provisional

Archaeology

Palaeontology Palaeontology

Heritage areas

Burial grounds

Protected areas

monuments and

Heritage objects heritage(S. sites Surface or vegetation clearing 0 0 0 0 0 1 2 1 0 1 0 ahead of construction Damage to or the destruction Construction of of heritage 0 0 0 0 0 1 2 1 0 1 0 access roads resources Establishment of gas exploration 0 0 0 0 0 1 2 3 1 wells

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7 Proposed Way Forward Digby Wells will complete a HIA and PIA in compliance with Section 38(8) of the NHRA in support of the EIA for the Project. Digby Wells. Digby Wells will submit the HIA and PIA, together with the EIA report and supporting specialist studies, to the relevant heritage authorities for Statutory Comment. In compliance with the requirements encapsulated in Section 38(8) of the NHRA, the HIA and PIA process will include the following:

● In-field assessment of the Project area with specific reference to the proposed infrastructure layout. This will include a pre-disturbance survey aimed at identifying cultural heritage resources within the Project area that may be impacted by the Project; and

● Assigning Cultural Significance (CS) values to and proposing Field Ratings for heritage resources identified in the pre-disturbance survey considering Sections 3 and 7 of the NHRA respectively;

● Assessing the impacts to heritage resources using the Shango Solutions impact assessment method (refer to Appendix B), considering the CS of the affected heritage resources;

● Developing reasonable and feasible management measures and mitigation strategies; and

● A specialist desktop PIA process to address the requirements of the South African Heritage Resources Information System (SAHRIS) Palaeosensitivity Map (PSM).

8 Conclusion The aim of the HSR was to develop a cultural heritage baseline of the site-specific study area while considering the larger local and regional context. The identified baseline was used to complete the primary assessment of the potential risks, possible impacts and high-level scoping assessment to inform the proposed way forward, which will include an EIA and HIA phase. Based on the Project description, Digby Wells is of the opinion that there is potential to alter the current status quo of heritage resources identified within the site-specific study area. The potential impacts posed by Project activities to the heritage resources require an assessment to provide reasonable and feasible mitigation and management measures aimed at removing or reducing the intensity of the potential impacts. The HIA report will consider impacts to cultural heritage resources and a PIA report will consider impacts to the fossil heritage resources.

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9 Works Cited Behrens, J. & Swanepoel, N., 2008. Historical archaeologies of southern Africa: precedents and prospects. In: N. Swanepoel, A. Esterhuysen & P. Bonner, eds. Five Hundred Years Rediscovered: South African precedents and prospects. Johannesburg: Wits University Press, pp. 23-39. Clark, J., 1982. The cultures of the Middle Palaeolithic/Middle Stone Age. In: J. Clark, ed. The Cambridge History of Africa, Volume 1: From the Earliest Times to c. 500 BC. Cambridge: Cambridge University Press, pp. 248-341. Daniels, E., 2013. NW-STM-1209-1876-00005 Distribution Environmental Screening Document, Bethlehem CNC: Distribution Environmental Screening Document. SAHRIS Case ID: 3332. Daniels, E. & Tomsana, A., 2014. VM88-86-152 Refurbishment Distribution Environmental Screening Document, Bothaville CNC: Distribution Environmental Screening Document. SAHRIS Case ID: 5659. Deacon, H. & Deacon, J., 1999. Human Beginnings in South Africa. Cape Town: David Phillip. Delius, P. & Cope, R., 2007. Hard-fought frontiers: 1845 - 1883. In: Mpumalanga: History and Heritage.. Pietermaritzburg: University of KwaZulu-Natal Press, pp. 137-199. Delius, P., Maggs, T. & Schoeman, A., 2014. Forgotten World: The Stone-walled Settlements of the Mpumalanga Escarpment. First ed. Johannesburg: Wits University Press. Dreyer, C., 2006a. First Phase Archaeological and Cultural Heritage Assessment of the proposed Residential Developments at the farm Boschpunt 2218, Kroonstad, Free State, Cobus Dreyer: Unpublished report prepared for Global Green Environmental Consultants and LMV Environmental Consultants. SAHRIS Map ID: 01496. Dreyer, C., 2006b. First Phase Archaeological and Cultural Heritage Assessment of the Proposed Residential Developments at the farm Middenspruit 151, Kroonstad, Free State, Cobus Dreyer: Unpublished report prepared for Global Green Environmental Consultants and LMV Environmental Consultants. SAHRIS Map ID: 01566. Dreyer, C., 2007. Archaeological and Cultural Heritage Assessment of the Proposed Residential Developments at Petrus Steyn, Free State, Cobus Dreyer: Unpublished report prepared for Phethogo Consulting. SAHRIS Map ID: 01812. Dreyer, C., 2008. Archaeological and Cultural Heritage Assessment of the Proposed Poultry Farm at Roodekraal 474, Senekal, Free State, Cobus Dreyer: Unpublished report prepared for MDA Environmental Consultants. SAHRIS Map ID: 01608. Du Bruyn, C. & Mosweu, K., 2019. Heritage Impact Assessment for the Amendment of an Existing Propsecting Right and Environmental Authorisation for Bothaville NE Ext. A situated in the Free State Province, NGT ESHS Solutions: Unpublished report prepared for Shango Solutions (Pty) Ltd. SAHRIS Case ID: 13583.

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Esterhuysen, A. & Smith, J., 2007. Stories in Stone. In: P. Delius, ed. Mpumalanga: History and Heritage: reclaiming the past, defining the future. Pietermatiztburg: University of KwaZulu- Natal Press, pp. 41-67. Fairbridge, D., 1918. History of South Africa. London: Oxford University Press. Genealogical Society of South Africa, 2011. Google Earth Cemetery Initiative. Google Earth Database: Genealogical Society of South Africa Database. Groenwald, G. & Groenewald, D., 2014. SAHRA Palaeotechnical Report: Palaeontological Heritage of the Free State, Report generated for the South African Heritage Resouces Agency: Available from the South African Heritage Resources Information System. Huffman, T., 2007. The Handbook to the Iron Age: The Archaeology of Pre-Colonial Farming Societies in Southern Africa. Pietermaritzburg: Univerity of KwaZulu-Natal Press. Johnson, M. R., Anhauesser, C. R. & Thomas, R. J., 2006. The Geology of South Africa. 2009 Reprint (with minor corrections) ed. Johannesburg: Council for Geosciences. Kruger, N., 2018. Archaeological Impact Assessment (AIA) of Demarcated Areas on a Portion of Portion 1 of the Farm Middenspruit 151 for the proposed Middenspruit Rock Mine Project in the Fezile Dabi District Municipality, Free State Province, Exigo Sustainability: Unpublished report prepared for LW Consultants. SAHRIS Case ID: 11817. Landau, P., 2010. Popular politics in the history of South Africa: 1400-1948. Cambridge: Cambridge University Press. Maggs, T., 1976. Iron Age Communities of the Southern Highveld. Pietermaritzburg: Natal Museum. Mitchell, P., 2002. The Archaeology of Southern Africa. Cambridge: Cambridge University Press. Pistorius, J. C., 2004. A Heritage Impact Assessment (HIA) Study for an EMP for the Voorspoed Diamond Mine near Kroonstad in the Free State Province of South Africa, Dr Julius CC Pistorius: Unpublished report prepared for Metago Environmental Engineers. SAHRIS Case ID: 3169. SAHRA, 2017. PalaeoSensitivity Map. [Online] Available at: http://www.sahra.org.za/sahris/map/palaeo [Accessed 23 March 2020]. Sebogodi, W., 2014. BW408 Refurbishment Distribution Environmental Screening Document, Bothaville CNC: Distribution Environmental Screening Document. SAHRIS Case ID: 5818. Swanepoel, N., Esterhuysen, A. & Bonner, P., 2008. Five Hundred Years Rediscovered: Southern African Precedents and Prospects. Johannesburg: Wits University Press. Van Der Walt, J., 2013. Archaeological Impact Assessment for the Proposed Steynsrus (19.5 MW) Photovoltaic Plant, Free State Province, Heritage Contacts and Archaeological Consulting: Unpublished report prepared for Savannah Environmental (Pty) Ltd. SAHRIS Case ID: 3420 and 4560.

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WITS, 2010. Archaeological Site Database, Johannesburg: Department of Geography, Archaeology and Environmental Science.

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Appendix A: Specialist CVs

Miss Shannon Hardwick Heritage Resources Management Consultant Social and Heritage Services Digby Wells Environmental

1 Education

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

2013 MSc (Archaeology) University of the Witwatersrand

2010 BSc (Honours) (Archaeology) University of the Witwatersrand

2009 BSc University of the Witwatersrand

2006 Matric Rand Park High School

2 Language Skills

Language Written Spoken

English Excellent Excellent

Afrikaans Fair Basic

3 Employment

Period Company Title/position

Heritage Resources Management 2019 to Present Digby Wells Environmental Consultant

Assistant Heritage Resources 2017 to 2019 Digby Wells Environmental Management Consultant

2017 to 2017 Digby Wells Environmental Social and Heritage Services Intern

2016 to 2017 Tarsus Academy Facilitator

2011 to 2016 University of the Witwatersrand Teaching Assistant

2011 University of the Witwatersrand Collections Assistant

MAKING A DIFFERENCE 1 DIGBY WELLS ENVIRONMENTAL

4 Experience I joined the Digby Wells team in May 2017 as a Heritage Management Intern and has most recently been appointed as a Heritage Resources Management Consultant. I am an archaeologist and obtained a Master of Science (MSc) degree from the University of the Witwatersrand in 2013, specialising in historical archaeobotany in the Limpopo Province. I am a published co-author of one paper in Journal of Ethnobiology. Since joining Digby Wells, I have gained generalist experience through the compilation of various heritage assessments, including Notification of Intent to Develop (NIDs), Heritage Scoping Reports (HSRs), Heritage Impact Assessment (HIA) reports, Heritage Basic Assessment Reports (HBARs) and permit applications to undertake permitted activities in terms of Sections 34 and 35 of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA). I have also obtained experience in compiling socio-economic documents, including a Community Health, Safety and Security Management Plan (CHSSMP) and social baselines and data analysis for Projects in South Africa, Malawi, Mali and Sierra Leone. My fieldwork experience includes heritage pre-disturbance surveys in South Africa, Malawi and the Democratic Republic of the Congo and social fieldwork in Malawi. I am a registered member of the Association of Southern African Professional Archaeologists (ASAPA) and the International Council on Monuments and Sites (ICOMOS).

5 Project Experience My project experience is listed in the table below. Project Experience

Project / Project Date of Project Title Name of Client Experience Location Completion Description

Environmental Authorisation Ermelo, for the Dagsoom Coal Mining Dagsoom Coal Heritage Impact Mpumalanga Ongoing Project near Ermelo, Mining (Pty) Ltd Assessment Province Mpumalanga Province

Section 34 Permit Regional Tailings Storage Ergo Mining (Pty) Randfontein, Ongoing Application Facility Heritage Mitigations Ltd Gauteng Process

Weltervreden Mine Environmental Authorisation, Mbuyelo Group Belfast, Heritage Impact Ongoing Water Use Licence and Mining (Pty) Ltd Mpumalanga Assessment Right Application Project

MAKING A DIFFERENCE 2 DIGBY WELLS ENVIRONMENTAL

Project / Project Date of Project Title Name of Client Experience Location Completion Description

Environmental Authorisation Lephalale, for the proposed Lephalale MDT Environmental Notification of Limpopo 2019 Pipeline Project, Limpopo (Pty) Ltd Intent to Develop Province Province

Heritage Resources Exxaro Coal Kriel, Heritage Site Management Process Update Mpumalanga (Pty) Mpumalanga 2019 Management for the Exxaro Matla Mine Ltd Province Plan Update

Environmental Authorisation Vhembe District Heritage Impact for the proposed Musina- Limpopo Economic Municipality, Assessment Makhado Special Economic Development Ongoing Limpopo Project Zone Development Project, Agency Province Management Limpopo Province

Songwe Hills Rare Earth Mkango Resources Phalombe Heritage Impact Ongoing Elements Project Limited District, Malawi Assessment

Anker Coal and Clewer, Elandsfontein Colliery Burial Mineral Holdings Site Inspection Emalahleni, December Grounds and Graves Chance SA (Pty) Ltd Project Mpumalanga 2018 Finds Elandsfontein Management Province Colliery (Pty) Ltd

Environmental Authorisation Process to Decommission a Secunda, Sasol Mining (Pty) Notification of Conveyor Belt Servitude, Road Mpumalanga Ongoing Ltd Intent to Develop and Quarry at Twistdraai East Province Colliery

Environmental and Social Future Minerals Heritage Impact Impact Assessment for the Bougouni, Mali Ongoing S.A.R.L. Assessment Bougouni Lithium Project, Mali

Environmental Authorisation Nomalanga for the Nomalanga Estates Greytown. Heritage Impact Property Holdings Ongoing Expansion Project, KwaZulu- KwaZulu-Natal Assessment (Pty) Ltd Natal

Environmental Authorisation for the Temo Mine proposed Lephalale, Temo Coal Mining Heritage Impact Rail, Road and Pipeline Limpopo Ongoing (Pty) Ltd Assessment Development, Limpopo Province Province

MAKING A DIFFERENCE 3 DIGBY WELLS ENVIRONMENTAL

Project / Project Date of Project Title Name of Client Experience Location Completion Description

Kibali Sector, Randgold Democratic December Resettlement Gorumbwa RAP Audit Resources Limited Republic of the 2018 Action Plan Audit Congo

Sasol Sigma Defunct Colliery Surface Mitigation Project: Sasol Mining (Pty) Sasolburg, Free November Notification of Proposed Rover Diversion and Ltd State Province 2018 Intent to Develop Flood Protection Berms

Basic Assessment and Regulation 31 Amendment / Sasol Mining (Pty) Sasolburg, Free Notification of Consolidation for Sigma Ongoing Ltd State Province Intent to Develop Colliery: Mooikraal and Sigma Colliery: 3 Shaft

Sasol Mining Sigma Colliery Heritage Basic Ash Backfilling Project, Sasol Mining (Pty) Sasolburg, Free July 2018 Assessment Sasolburg, Free State Ltd State Province Report Update Province

Constructed Landfill Site for Southern the Sierra Rutile Limited Sierra Rutile Social Impact Province, Sierra May 2019 Mining Operation, Southern Limited Assessment Leone Province, Sierra Leone

Environmental Impact Assessment for the Klipspruit Ogies, Notification of South32 SA Coal Colliery Water Treatment Plant Mpumalanga Ongoing Intent to Develop; Holdings (Pty) Ltd and associated pipeline, Province Social baseline Mpumalanga

Proposed construction of a Water Treatment Plant and Newcastle, associated infrastructure for Eskom Holdings Heritage Impact KwaZulu-Natal Ongoing the Treatment of Mine-Affected SOC Limited Assessment Province Water at the Kilbarchan Colliery

Exxaro Coal Belfast, Section 34 Permit Belfast Implementation Project Mpumalanga (Pty) Mpumalanga Ongoing Application Ltd Province

MAKING A DIFFERENCE 4 DIGBY WELLS ENVIRONMENTAL

Project / Project Date of Project Title Name of Client Experience Location Completion Description

GCS Water and Newcastle, Heritage Impact Newcastle Landfill Project Environmental March 2019 KwaZulu-Natal Assessment Consultants

NHRA Section 34 Permit Application process for the Johannesburg, Section 34 Permit Davin and Queens Court IDC Architects Gauteng May 2018 Application Buildings on Erf 173 and 174, Province Process West Germiston, Gauteng Province

Basic Assessment and Environmental Management Plan for the Proposed pipeline Ogies, Heritage Basic HCI Coal (Pty) Ltd February from the Mbali Colliery to the Mpumalanga Assessment Mbali Colliery 2018 Tweefontein Water Province Report Reclamation Plant, Mpumalanga Province

The South African Radio Heritage Impact Astronomy Observatory The South African Carnarvon, Assessment; Square Kilometre Array Radio Astronomy Northern Cape July 2018 Conservation Heritage Impact Assessment Observatory Province Management and Conservation (SARAO) Plan Management Plan Project

Heritage Impact Environmental Impact Assessment Rustenburg, Assessment for the proposed Sun International Conservation North West Ongoing Future Developments within (Pty) Ltd Management Province the Sun City Resort Complex Plan Social Baseline

Environmental Fatal Flaw Waterberg, November Fatal Flaw Analysis for the Mabula Filling Mr van den Bergh Limpopo 2017 Analysis Station Province

Environmental Impact Assessment for the Blyvoor Notification of Blyvoor Gold Carletonville, Gold Mining Project near Ongoing Intent to Develop; Capital (Pty) Ltd Gauteng Carletonville, Gauteng Social Baseline Province

MAKING A DIFFERENCE 5 DIGBY WELLS ENVIRONMENTAL

Project / Project Date of Project Title Name of Client Experience Location Completion Description

Heritage Resources Exxaro Coal Kriel, October Heritage Impact Management Process for the Mpumalanga (Pty) Mpumalanga 2018 Assessment Exxaro Matla Mine Ltd Province

Community Health, Safety Liwonde, Liwonde Additional Studies Mota-Engil Africa June 2018 and Security Malawi Management Plan

Environmental Impact Randfontein, December Heritage Impact Assessment for the Millsite Sibanye-Stillwater Gauteng 2017 Assessment TSF Complex

Heritage Resources Management Process for the Ekurhuleni Portion 296 of the farm Shuma Africa Notification of (Johannesburg), June 2017 Zuurfontein 33 IR Proposed Projects (Pty) Ltd Intent to Develop Gauteng Residential Establishment Project

NHRA Section 35 Rustenburg, Archaeological Archaeological Investigations, Lanxess Chrome North West August 2017 Phase 2 Lanxess Chrome Mine, North- Mine (Pty) Ltd Province Mitigation West Province

Pre-Feasibility Environmental and Social Input October Study; Heritage Birimium Gold Bougouni, Mali for the Pre-Feasibility Study 2018 Impact Assessment

6 Professional Registration

Position Professional Body Member Number

Association of Southern African Professional Archaeologists 451 Member (ASAPA)

Member International Council on Monuments and Sites (ICOMOS) 38048

MAKING A DIFFERENCE 6 DIGBY WELLS ENVIRONMENTAL

7 Publications Esterhuysen, A.B. & Hardwick, S.K. 2017. Plant remains recovered from the 1854 siege of the Kekana Ndebele, Historic Cave, Makapan Valley, South Africa. Journal of Ethnobiology 37(1): 97-119.

MAKING A DIFFERENCE 7 DIGBY WELLS ENVIRONMENTAL

Mr. Justin du Piesanie Divisional Manager Social and Heritage Services Digby Wells Environmental

1 Education

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

2015 Continued Professional Development, Intermediate PM.Ideas: A division of the Project Management Course Mindset Group

2013 Continued Professional Development Programme, University of Cape Town Architectural and Urban Conservation: Researching and Assessing Local Environments

2008 MSc University of the Witwatersrand

2005 BA (Honours) (Archaeology) University of the Witwatersrand

2004 BA University of the Witwatersrand

2001 Matric Norkem Park High School

2 Language Skills

Language Written Spoken

English Excellent Excellent

Afrikaans Proficient Good

MAKING A DIFFERENCE 1 DIGBY WELLS ENVIRONMENTAL

3 Employment

Period Company Title/position

2018 to present Digby Wells Environmental Divisional Manager: Social and Heritage Services

2016-2018 Digby Wells Environmental Unit Manager: Heritage Resources Management

2011-2016 Digby Wells Environmental Heritage Management Consultant: Archaeologist

2009-2011 University of the Witwatersrand Archaeology Collections Manager

2009-2011 Independent Archaeologist

2006-2007 Maropeng & Sterkfontein Caves UNESCO Tour guide World Heritage Site

4 Experience I joined the company in August 2011 as an archaeologist. Subsequently, Digby Wells appointed me as the Heritage Unit Manager and Divisional Manager for Social and Heritage Services in 2016 and 2018 respectively. I obtained my Master of Science (MSc) degree in Archaeology from the University of the Witwatersrand in 2008, specialising in the Southern African Iron Age. I further attended courses in architectural and urban conservation through the University of Cape Town’s Faculty of Engineering and the Built Environment Continuing Professional Development Programme in 2013. I am a professional member of the Association of Southern African Professional Archaeologists (ASAPA), and accredited by the association’s Cultural Resources Management (CRM) section. I am also a member of the International Council on Monuments and Sites (ICOMOS), an advisory body to the UNESCO World Heritage Convention. I have over 10 years combined experience in HRM in South Africa, including heritage assessments, archaeological mitigation, grave relocation, and NHRA Section 34 application processes. I gained further generalist experience since my appointment at Digby Wells in Botswana, Burkina Faso, Cameroon, the Democratic Republic of Congo, Liberia, Malawi, Mali, Senegal and Tanzania on projects that have required compliance with IFC requirements such as Performance Standard 8: Cultural Heritage. Furthermore, I have acted as a technical expert reviewer of HRM projects undertaken in Cameroon and Senegal. As Divisional Manager for Social and Heritage Services at Digby Wells Environmental, I manage several large capital Projects and multidisciplinary teams placing me in the best position to identify and exploit points of integration between the HRM process and greater social landscape. This approach to HRM, as an integrated discipline, is grounded in

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international HRM principles and standards that has allowed me to provide comprehensive, project-specific solutions that promote ethical heritage management and assist in achieving the strategic objectives of our clients, as well as maintain or enhance Cultural Significance of the relevant cultural heritage resources.

5 Project Experience Please see the following table for relevant Project experience:

PROJECT LOCATION DATES PROJECT TYPE CLIENT

Kriel, Matla Mine 1 GRP Mpumalanga, 2020 - Grave Relocation Exxaro Coal Mpumalanga (Pty) Ltd South Africa

Middelburg, Mafube RAP and GRP Mpumalanga, 2019 - Grave Relocation Mafube Coal South Africa

Carnarvon, Heritage SARAO SKA Project: Northern 2019 - Management and SARAO Heritage Mitigations Cape, South Mitigation Africa

Orientale Province, Kibali Kalimva & Ikamva Heritage Impact Democratic 2019 2019 Barrick Gold Corporation Pit ESIA Assessment Republic of Congo

Johannesburg, Heritage Site Ergo City Deep HSMP Gauteng, 2019 2019 Ergo (Pty) Ltd Management Plan South Africa

Westonaria, Section 34 Ergo RTSF Section 34 Gauteng, 2019 - Destruction Permit Ergo (Pty) Ltd Process South Africa Applications

Ermelo, Heritage Impact Twyfelaar EIA Mpumalanga, 2019 2019 Dagsoom Coal Mining (Pty) Ltd Assessment South Africa

Sasolburg, Heritage Impact Sasol River Diversion Free State, 2019 2019 Sasol Mining Assessment South Africa

Pilanesberg, Heritage Impact North-West Assessment and Sun City EIA and CMP 2018 2019 Sun International Province, Conservation South Africa Management Plan

Heritage Impact Kriel, Assessment and Exxaro Coal Mpumalanga (Pty) Exxaro Matla HRM Mpumalanga, 2017 2019 Conservation Ltd South Africa Management Plan

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PROJECT LOCATION DATES PROJECT TYPE CLIENT

Belfast, Exxaro Coal Mpumalanga (Pty) Exxaro Belfast GRP Mpumalanga, 2013 2019 Grave Relocation Ltd South Africa

KwaZulu- Eskom Northern KZN Heritage Impact Natal, South 2016 2018 ILISO Consulting Strengthening Assessment Africa

Lephalale, Limpopo Thabametsi GRP 2017 2018 Grave Relocation Exxaro Resources Ltd Province, South Africa

Carnarvon, Heritage Impact Northern Assessment and SKA HIA and CMP 2017 2018 SARAO Cape, South Conservation Africa Management Plan

Lephalale, Grootegeluk Watching Limpopo 2017 2017 Watching Brief Exxaro Resources Ltd Brief Province, South Africa

Kriel, Mpumalanga Heritage Site Exxaro Coal Mpumalanga (Pty) Matla HSMP 2017 2017 Province, Management Plan Ltd South Africa

Lephalale, Ledjadja Coal Borrow Limpopo Heritage Basic 2017 2017 Ledjadja Coal (Pty) Ltd Pits Province, Assessment South Africa

Exxaro Belfast Belfast, Palaeontological Exxaro Coal Mpumalanga (Pty) Implementation Project Mpumalanga, 2017 2017 Impact Assessment Ltd PIA South Africa

Rustenburg, Lanxess Chrome Mine North West Archaeological 2017 2017 Phase 2 Excavations Lanxess Chrome Mine (Pty) Ltd Province, Mitigation South Africa

KwaZulu- Tharisa Apollo EIA Heritage Impact Natal, South 2017 2017 GCS (Pty) Ltd Project Assessment Africa

Germiston, Section 34 Queen Street Section Johannesburg, 2017 2017 Destruction Permit IDC Architects 34 Process Gauteng, Applications South Africa

Goulamina, Heritage Impact Goulamina EIA Project Sikasso 2017 2017 Birimian Limited Assessment Region, Mali

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PROJECT LOCATION DATES PROJECT TYPE CLIENT

Ekurhuleni, Zuurfontein Residential Notification of Intent Gauteng, 2017 2017 Shuma Africa Projects Establishment Project to Develop South Africa

Orientale Kibali Grave Relocation Province, Training and Democratic 2017 2017 Grave Relocation Randgold Resources Limited Implementation Republic of Congo

Heritage Impact Massawa EIA Senegal 2016 2017 Assessment and Randgold Resources Limited Technical Reviewer

Welkom, Free Heritage Impact Beatrix EIA and EMP State, South 2016 2017 Sibanye Stillwater Assessment Africa

Pilanesberg, Notification of Intent North-West to Develop and Sun City Chair Lift 2016 2017 Sun International Province, Heritage Basic South Africa Assessment

Hendrina, Hendrina Underground Heritage Impact Mpumalanga, 2016 2017 Umcebo Mining (Pty) Ltd Coal Mine EIA Assessment South Africa

Clewer, Elandsfontein EMP Heritage Impact Mpumalanga, 2016 2017 Anker Coal Update Assessment South Africa

Limpopo Groningen and Heritage Basic Rustenburg Platinum Mines Province, 2016 2016 Inhambane PRA Assessment Limited South Africa

Springs, Heritage Impact Palmietkuilen MRA Gauteng, 2016 2016 Canyon Resources (Pty) Ltd Assessment South Africa

Copper Sunset Sand Free State, Heritage Basic 2016 2016 Copper Sunset Sand (Pty) Ltd Mining S.102 South Africa Assessment

Springs, Notification of Intent Grootvlei MRA Gauteng, 2016 2016 Ergo (Pty) Ltd to Develop South Africa

Mpumalanga, Palaeontological Lambda EMP 2016 2016 Eskom Holdings SOC Limited South Africa Impact Assessment

Newcastle, Kilbarchan Basic KwaZulu- Heritage Basic 2016 2016 Eskom Holdings SOC Limited Assessment and EMP Natal, South Assessment Africa

Grootegeluk Lephalale, Notification of Intent 2016 2016 Exxaro Coal Resources (Pty) Ltd Amendment Limpopo to Develop

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PROJECT LOCATION DATES PROJECT TYPE CLIENT Province, South Africa

Pretoria, Garsfontein Township Notification of Intent Gauteng, 2016 2016 Leungo Construction Enterprises Development to Develop South Africa

Johannesburg, Louis Botha Phase 2 Gauteng, 2016 2016 Phase 2 Excavations Royal Haskoning DHV South Africa

Pilanesberg, Sun City Heritage North-West 2016 2016 Phase 2 Mapping Sun International Mapping Province, South Africa

Heritage Impact Gino’s Building Section Johannesburg, Assessment and 34 Destruction Permit Gauteng, 2015 2016 Section 34 Bigen Africa Services (Pty) Ltd Application South Africa Destruction Permit Application

Heritage Impact Johannesburg, EDC Block Assessment and Gauteng, 2015 2016 Bigen Africa Services (Pty) Ltd Refurbishment Project Section 34 Permit South Africa Application

Steenbokpan, Namane IPP and Limpopo Heritage Impact 2015 2016 Namane Resources (Pty) Ltd Transmission Line EIA Province, Assessment South Africa

Steenbokpan, Temo Coal Road Limpopo Heritage Impact Diversion and Rail Loop 2015 2016 Namane Resources (Pty) Ltd Province, Assessment EIA South Africa

Gauteng, Heritage Impact Sibanye WRTRP 2014 2016 Sibanye Stillwater South Africa Assessment

NTEM Iron Ore Mine Cameroon 2014 2016 Technical Review IMIC plc and Pipeline Project

NLGM Constructed Heritage Impact Liberia 2015 2015 Aureus Mining Wetlands Project Assessment

ERPM Section 34 Johannesburg, Section 34 Destruction Permits Gauteng, 2015 2015 Destruction Permit Ergo (Pty) Ltd Applications South Africa Applications

Heritage Impact JMEP II EIA Botswana 2015 2015 Jindal Assessment

Bronkhorstspr Heritage Impact Oakleaf ESIA Project uit, Gauteng, 2014 2015 Oakleaf Investment Holdings Assessment South Africa

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PROJECT LOCATION DATES PROJECT TYPE CLIENT

Kriel, Heritage Impact Imvula Project Mpumalanga, 2014 2015 Ixia Coal Assessment South Africa

Mokopane, VMIC Vanadium EIA Heritage Impact Limpopo, 2014 2015 VM Investment Company Project Assessment South Africa

Steelpoort, Everest North Mining Heritage Impact Mpumalanga, 2012 2015 Aquarius Resources Project Assessment South Africa

Orientale Province, Nzoro 2 Hydro Power Democratic 2014 2014 Social consultation Randgold Resources Limited Project Republic of Congo

Springs, Eastern Basin AMD Heritage Impact Gauteng, 2014 2014 AECOM Project Assessment South Africa

Soweto, Soweto Cluster Heritage Impact Gauteng, 2014 2014 Ergo (Pty) Ltd Reclamation Project Assessment South Africa

Ogies, Heritage Impact Klipspruit South Project Mpumalanga, 2014 2014 BHP Billiton Assessment South Africa

Ogies, Klipspruit Extension: Heritage Impact Mpumalanga, 2014 2014 BHP Billiton Weltevreden Project Assessment South Africa

Ergo Rondebult Johannesburg, Heritage Basic Pipeline Basic 2014 2014 Ergo (Pty) Ltd South Africa Assessment Assessment

Orientale Province, Kibali ESIA Update Heritage Impact Democratic 2014 2014 Randgold Resources Limited Project Assessment Republic of Congo

Westonaria, GoldOne EMP Gauteng, 2014 2014 Gap analysis Gold One International Consolidation South Africa

Wakkerstroom Palaeontological Yzermite PIA , Mpumalanga, 2014 2014 EcoPartners Impact Assessment South Africa

Sasolburg, Sasol Mooikraal Basic Heritage Basic Free State, 2014 2014 Sasol Mining Assessment Assessment South Africa

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PROJECT LOCATION DATES PROJECT TYPE CLIENT

Johannesburg, Rea Vaya Phase II C Heritage Impact Gauteng, 2014 2014 ILISO Consulting Project Assessment South Africa

New Liberty Gold Liberia 2013 2014 Grave Relocation Aureus Mining Project

Putu Iron Ore Mine Petroken, Heritage Impact 2013 2014 Atkins Limited Project Liberia Assessment

Secunda, Notification of Intent Sasol Twistdraai Project Mpumalanga, 2013 2014 ERM Southern Africa to Develop South Africa

Orientale Province, Kibali Gold Hydro- Heritage Impact Democratic 2012 2014 Randgold Resources Limited Power Project Assessment Republic of Congo

SEGA Gold Mining Burkina Faso 2013 2013 Technical Reviewer Cluff Gold PLC Project

Breyton, Consbrey and Harwar Heritage Impact Mpumalanga, 2013 2013 Msobo Coal Collieries Project Assessment South Africa

Falea Uranium Mine Environmental Falea, Mali 2013 2013 Heritage Scoping Rockgate Capital Assessment

Daleside Acetylene Gas Gauteng, Heritage Impact 2013 2013 ERM Southern Africa Production Facility South Africa Assessment

SEGA Gold Mining Socio Economic and Burkina Faso 2012 2013 Cluff Gold PLC Project Asset Survey

Orientale Province, Kibali Gold Project Democratic 2011 2013 Grave Relocation Randgold Resources Limited Grave Relocation Plan Republic of Congo

Steelpoort, Everest North Mining Heritage Impact Mpumalanga, 2012 2012 Aquarius Resources Project Assessment South Africa

Environmental Authorisation for the Gauteng, Heritage Impact 2012 2012 Gold One International Gold One Geluksdal South Africa Assessment TSF and Pipeline

Mokopane, Platreef Burial Grounds Limpopo Burial Grounds and 2012 2012 Platreef Resources and Graves Survey Province, Graves Survey South Africa

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PROJECT LOCATION DATES PROJECT TYPE CLIENT

Limpopo Resgen Boikarabelo Province, 2012 2012 Phase 2 Excavations Resources Generation Coal Mine South Africa

Burgersfort, Bokoni Platinum Road Limpopo 2012 2012 Watching Brief Bokoni Platinum Mine Watching Brief Province, South Africa

Kwa-Zulu Transnet NMPP Line Natal, South 2010 2010 Heritage survey Umlando Consultants Africa

Archaeological Impact Johannesburg, Archaeological Assessment – Gauteng, 2010 2010 ARM Impact Assessment Witpoortjie Project South Africa

Der Brochen Steelpoort, Archaeological Mpumalanga, 2010 2010 Phase 2 Excavations Heritage Contracts Unit Excavations South Africa

De Brochen and Steelpoort, Site Recording: Booysendal Mpumalanga, 2010 2010 Heritage Contracts Unit Mapping Archaeology Project South Africa

Eskom Thohoyandou Limpopo Electricity Master Province, 2010 2010 Heritage Statement Strategic Environmental Focus Network South Africa

North-West Batlhako Mine Province, 2010 2010 Phase 2 Mapping Heritage Contracts Unit Expansion South Africa

Shoshanguve, Wenzelrust Excavations Gauteng, 2009 2009 Phase 2 Excavations Heritage Contracts Unit South Africa

University of the Parys, Free Witwatersrand Parys State, South 2009 2009 Phase 2 Mapping University of the Witwatersrand LIA Shelter Project Africa

Archaeological Johannesburg, Assessment of Heritage Basic Gauteng, 2008 2008 ARM Modderfontein AH Assessment South Africa Holdings

Thabazimbi, Heritage Assessment of Limpopo Heritage Impact 2008 2008 Rhino Mines Rhino Mines Province, Assessment South Africa

Thabazimbi, Limpopo Archaeological Cronimet Project 2008 2008 Cronimet Province, surveys South Africa

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PROJECT LOCATION DATES PROJECT TYPE CLIENT

Limpopo Eskom Thohoyandou Province, 2008 2008 Heritage Statement Eskom SEA Project South Africa

Witbank Dam Witbank, Archaeological Archaeological Impact Mpumalanga, 2007 2007 ARM survey Assessment South Africa

Sun City, Pilanesberg, Sun City Archaeological Site Recording: North West 2006 2006 Sun International Site Mapping Mapping Province, South Africa

Meyersdal, Klipriviersberg Archaeological Gauteng, 2005 2006 ARM Archaeological Survey surveys South Africa

6 Professional Registration

Position Professional Body Registration Number

Member Association for Southern African Professional 270 Archaeologists (ASAPA); ASAPA Cultural Resources Management (CRM) section

Member International Council on Monuments and Sites 14274 (ICOMOS)

Member Society for Africanist Archaeologists (SAfA) N/A

Member International Association of Impact Assessors 5494 (IAIA) South Africa

7 Publications Huffman, T.N. & du Piesanie, J.J. 2011. Khami and the Venda in the Mapungubwe Landscape. Journal of African Archaeology 9(2): 189-206 du Piesanie, J.J., 2017. Book Review: African Cultural Heritage Conservation and Management. South African Archaeological Bulletin 72(205)

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Appendix B: HRM Methodology

Cultural Significance, Field Rating and Impact Assessment

Methodology Statement

Project Number: ZZZ9999

Prepared for: Internal Document

June 2019

______Digby Wells and Associates (South Africa) (Pty) Ltd Co. Reg. No. 2010/008577/07. Turnberry Office Park, 48 Grosvenor Road, Bryanston, 2191. Private Bag X10046, Randburg, 2125, South Africa Tel: +27 11 789 9495, Fax: +27 11 069 6801, [email protected], www.digbywells.com ______Directors: GE Trusler (C.E.O), LF Stevens, J Leaver (Chairman)*, NA Mehlomakulu*, DJ Otto *Non-Executive ______

This document has been prepared by Digby Wells Environmental.

Report Type: Methodology Statement

Project Name: Cultural Significance, Field Rating and Impact Assessment

Project Code: ZZZ9999

Revision History

Name Responsibility Version Date

Ver. 1 May 2014 Johan Nel HRM Unit Manager Ver. 2 October 2014 ASAPA Member 095 Ver. 3 May 2015

Ver. 4 January 2016

Justin du Piesanie Divisional Manager: Social Ver. 5 June 2016 ASAPA Member 270 and Heritage Services Ver. 6 June 2019

This report is provided solely for the purposes set out in it and may not, in whole or in part, be used for any other purpose without Digby Wells Environmental prior written consent.

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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999

TABLE OF CONTENTS

1 Introduction ...... 1

2 Evaluation of Cultural Significance and Field Ratings ...... 1

2.1 Cultural Significance Determination ...... 1 2.2 Field Rating Determination ...... 2 3 Impact Assessment Methodology ...... 4

3.1 Categorising Impacts to Cultural Heritage ...... 6 3.2 Impact Assessment ...... 7 4 Recommended Management and Mitigation Measures ...... 11

LIST OF FIGURES

Figure 2-2: Field Ratings Methodology ...... 2 Figure 2-1: CS Determination Methodology ...... 3 Figure 3-1: Graphical Representation of Impact Assessment Concept ...... 5 Figure 3-2: Example of how Potential Impacts are considered ...... 5

LIST OF TABLES

Table 3-1: Description of Duration, Extent, Intensity and Probability Ratings Used in the Impact Assessment ...... 8 Table 3-2: Impact Significance Scores, Descriptions and Ratings ...... 10 Table 3-3 Relationship between Consequence, Probability and Significance ...... 10 Table 4-1: Minimum Recommended Management or Mitigation Requirements Considering CS ...... 11

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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999

1 Introduction Cultural heritage resources are intrinsic to the history and beliefs of communities. They characterise community identity and cultures, are finite, non-renewable and irreplaceable. Considering the innate value of cultural heritage resources, Heritage Resources Management (HRM) acknowledges that these have lasting worth as evidence of the origins of life, humanity and society. It is incumbent of the assessor to determine the cultural significance1 (CS) of cultural heritage resources to allow for the implementation of appropriate management. This is achieved through assessing cultural heritage resources’ value relative to certain prescribed criteria encapsulated in policies and legal frameworks, such as the South African National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA). Commensurate to the NHRA, with specific reference to Section 38, this methodology aims to ensure that clients protect cultural heritage during implementation of project activities by either avoiding, removing or reducing the intensity of adverse impacts to tangible2 and intangible3 cultural heritage resources within the defined area of influence. The methodology to define CS and assess the potential effects of a project is discussed separately in the sections below.

2 Evaluation of Cultural Significance and Field Ratings

2.1 Cultural Significance Determination Digby Wells developed a CS Determination Methodology to assign identified cultural heritage resources with a numerical CS rating in an objective as possible way and that can be independently reproduced provided that the same information sources are used, should this be required. This methodology determines the intrinsic, comparative and contextual significance of identified cultural heritage resources by considering their: 1. Importance rated on a six-point scale against four criteria; and 2. Physical integrity rated on a five-point scale.

1 Cultural significance is defined as the intrinsic “aesthetic, architectural, historical, scientific, social, spiritual, linguistic or technological value or significance” of a cultural heritage resource. These attributes are combined and reduced to four themes used in the Digby Wells significance matrix: aesthetic, historical, scientific and social. 2 (i) Moveable or immovable objects, property, sites, structures, or groups of structures, having archaeological (prehistoric), paleontological, historical, cultural, artistic, and religious values; (ii) unique natural features or tangible objects that embody cultural values, such as sacred groves, rocks, lakes, and waterfalls. 3 Cultural knowledge, innovations, and practices of communities embodying traditional lifestyles.

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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999

The assigned ratings consider information obtained through a review of available credible sources and representativity or uniqueness (i.e. known examples of similar resources to exist), as well as the current preservation status-quo as observed. Figure 2-2 depicts the CS formula and importance criteria, and it describes ratings on the importance physical integrity scales

2.2 Field Rating Determination Grading of heritage resources remains the responsibility of heritage resources authorities. However, the South African Heritage Resources Agency (SAHRA) Minimum Standards requires heritage reports include Field Ratings for identified resources to comply with section 38 of the NHRA. Section 7 of the NHRA provides for a system of grading of heritage resources that form part of the national estate and distinguishes between three categories. The field rating process is designed to provide a numerical rating of the recommended grading of identified heritage resources. The evaluation is done as objectively as possible by integrating the field rating into the significance matrix. Field ratings guide decision-making in terms of appropriate minimum required mitigation measures and consequent management responsibilities in accordance with Section 8 of the NHRA. Figure 2-1 presents the formula and the parameters used to determine the Field Ratings.

Figure 2-1: Field Ratings Methodology

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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999

Figure 2-2: CS Determination Methodology

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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999

3 Impact Assessment Methodology The rationale behind CS determination recognises that the value of a cultural heritage resource is a direct indication of its sensitivity to change (impacts) as well as the maximum acceptable levels of change to the resource. Therefore, the assessor must determine CS prior to the completion of any impact assessment. These requirements in terms of international best practice standards are integrated into the impact assessment methodology to guide both assessments of impacts and recommendations for mitigation and management of resources. The following are terms and definitions applicable to the Environmental Impact Assessment (EIA) concept (ISO 14001): ■ Project Activity: Activities associated with the Project that result in an environmental interaction during various phases, i.e. construction, operation and decommissioning, e.g., new processing plant, new stockpiles, development of open pit, dewatering, water treatment plant; ■ Environmental Interaction: An element or characteristic of an activity, product, or service that interacts or can interact with the environment. Environmental interactions can cause environmental impacts (but may not necessarily do so). They can have either beneficial impacts or adverse impacts and can have a direct and decisive impact on the environment or contribute only partially or indirectly to a larger environmental change; ■ Environmental Aspect: Various natural and human environments that an activity may interact with. These environments extend from within the activity itself to the global system, and include air, water, land, flora, fauna (including people) and natural resources of all kinds; and ■ Environmental Impact: A change to the environment that is caused either partly or entirely by one or more environmental interactions. An environmental interaction can have either a direct and decisive impact on the environment or contribute only partially or indirectly to a larger environmental change. In addition, it can have either a beneficial environmental impact or an adverse environmental impact.

The assessment process identified potential issues and impacts through examination of: ■ Project phases and activities, ■ Interactions between activities and the environmental aspect; and ■ The interdependencies between environmental aspects.

Figure 3-1 presents a graphical summary of this concept and Figure 3-2 provides an example of the process.

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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999

Figure 3-1: Graphical Representation of Impact Assessment Concept

Project Activity & Interaction Environmental Aspect Potential Environmental Impact

Issue Potential Impact Aspect Interdependencies Project Phase Activity

This relates to the This refers to one This identifies This identifies The issues Potential impacts consideration of or more of the and considers the and considers the considers the are a culmination the relevant activities that will various aspects interdepndencies activity in relation of the various phase of the be undertaken that will be between the to the identified categories project. during the affected by the various aspects aspects and evaluated as part Example: corresponding project activity. and how they interdepndencies. of the impact Construction phase of the Example: may be impacted Note: Activities assessment. project. Heritage, upon by the and Aspects can Example: Topsoil Example: Topsoil Biophysical, and relevant activity. have several clearing will clearing Social Example: issues resulting in remove Removal of various impacts. medicinal plants topsoil will Example: that will erode impact on flora Physical indigenous which may have alteration of the knowledge heritage and land systems and social cultural implications significance.

Figure 3-2: Example of how Potential Impacts are considered

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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999

3.1 Categorising Impacts to Cultural Heritage Impacts may manifest differently among geographical areas and diverse communities. For instance, impacts to cultural heritage resources can simultaneously affect the tangible cultural heritage resource and have social repercussions. The severity of the impact is compounded when the intensity of physical impacts and social repercussions differ significantly, e.g. removal of a grave surface dressings results in a minor physical impact but has a significant social impact. In addition, impacts to cultural heritage resources can influence the determined CS without a physical impact taking place. Given this reasoning, impacts as considered here are generally placed into three broad categories (adapted from Winter & Bauman 2005: 36): ■ Direct or primary impacts affect the fabric or physical integrity of the cultural heritage resource, for example destruction of an archaeological site or historical building. Direct or primary impacts may be the most immediate and noticeable. Such impacts are usually ranked as the most intense, but can often be erroneously assessed as high-ranking. For example, the destruction of a low-density scatter of archaeological material culture may be assessed as a negatively high impact if CS is not considered; ■ Indirect, induced or secondary impacts can occur later in time or at a different place from the causal activity, or because of a complex pathway. For example, restricted access to a cultural heritage resource resulting in the gradual erosion of its CS that may be dependent on ritual patterns of access. Although the physical fabric of the cultural heritage resource is not affected through any primary impact, its CS is affected, which can ultimately result in the loss of the resource itself; and ■ Cumulative impacts result from in-combination effects on cultural heritage resources acting within a host of processes that are insignificant when seen in isolation, but which collectively have a significant effect. Cumulative effects can be: ▪ Additive: the simple sum of all the effects, e.g. the total number of development activities that will occur within the study area; ▪ Synergistic: effects interact to produce a total effect greater than the sum of the individual effects, e.g. the effect of each different activity on the archaeological landscape in the study area; ▪ Time crowding: frequent, repetitive impacts on a cultural heritage resource at the same time, e.g. the effect of regular blasting activities on a nearby rock art site or protected historical building; ▪ Neutralizing: where the effects may counteract each other to reduce the overall effect, e.g. the effect of changes in land use could reduce the overall impact on sites within the archaeological landscape of the study area; and/or

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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999

▪ Space crowding: high spatial density of impacts on a cultural heritage resource, e.g. density of new buildings resulting in suburbanisation of a historical rural landscape.

The fact that cultural heritage resources do not exist in isolation from the wider natural, social, cultural and heritage landscape demonstrates the relevance of the above distinctions: CS is therefore also linked to rarity / uniqueness, physical integrity and importance to diverse communities.

3.2 Impact Assessment The impact assessment process is designed to provide a numerical rating of the identified potential impacts. This methodology follows the established impact assessment formula:

Impact = consequence of an event x probability of the event occurring

where:

Consequence = type of impact x (Duration + Extent + Intensity)

and

Probability = Likelihood of an impact occurring

In the formula for calculating consequence:

Type of impact = +1 (positive) or -1 (negative)

Table 3-1 presents a description of the duration, extent, intensity and probability ratings. The intensity rating definitions consider the determined CS of the identified cultural heritage resources. These criteria are used to determine the impact ratings as defined in Table 3-2 below. Table 3-3 represents the relationship between consequence, probability and significance. The impact assessment process considers pre- and post-mitigation scenarios with the intention of managing and/or mitigating impacts in line with the EIA Mitigation Hierarchy, i.e. avoiding all impacts on cultural heritage resources. Where Project-related mitigation does not avoid or sufficiently minimise negative impacts on cultural heritage resources, mitigation of these resources may be required.

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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999

Table 3-1: Description of Duration, Extent, Intensity and Probability Ratings Used in the Impact Assessment

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

Probability Description Exposure Description Intensity Description Probability Description

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

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

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

Impacts on heritage resources will have regional Major change to Heritage Could happen. Impact will remain for >50% - 4 Long Term Municipal area repercussions, issues or Moderately high Resource with Medium- Probable Has occurred here or Project Life effects, i.e. in context of the Medium High Value elsewhere regional study area.

Has not happened yet, but Impacts on heritage resources Moderate change to Heritage could happen once in a lifetime Impact will remain for >10% - will have local repercussions, Unlikely / Low 3 Medium Term Local Moderate Resource with Medium - of the project. 50% of Project Life issues or effects, i.e. in context probability Medium High Value There is a possibility that the of the local study area. impact will occur.

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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999

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

Probability Description Exposure Description Intensity Description Probability Description

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

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

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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999

Table 3-2: Impact Significance Scores, Descriptions and Ratings

Score Description Rating

109 to 147 A very beneficial impact which may be sufficient by itself to justify implementation of the project. The impact may result in permanent positive change. Major (positive)

A beneficial impact which may help to justify the implementation of the project. These impacts would be considered by society as constituting a major and usually a long-term positive change to the 73 to 108 Moderate (positive) heritage resources.

An important positive impact. The impact is insufficient by itself to justify the implementation of the project. These impacts will usually result in positive medium to long-term effect on the heritage 36 to 72 Minor (positive) resources.

3 to 35 A small positive impact. The impact will result in medium to short term effects on the heritage resources. Negligible (positive)

An acceptable negative impact for which mitigation is desirable but not essential. The impact by itself is insufficient even in combination with other low impacts to prevent the development being -3 to -35 Negligible (negative) approved. These impacts will result in negative medium to short term effects on the heritage resources.

An important negative impact which requires mitigation. The impact is insufficient by itself to prevent the implementation of the project but which in conjunction with other impacts may prevent its -36 to -72 Minor (negative) implementation. These impacts will usually result in negative medium to long-term effect on the heritage resources.

A serious negative impact which may prevent the implementation of the project. These impacts would be considered by society as constituting a major and usually a long-term change to the heritage -73 to -108 Moderate (negative) resources and result in severe effects.

-109 to - A very serious negative impact which may be sufficient by itself to prevent implementation of the project. The impact may result in permanent change. Very often these impacts are immitigable and Major (negative) 147 usually result in very severe effects.

Table 3-3 Relationship between Consequence, Probability and Significance

Relationship between consequence, probability and significance ratings

Significance

7 -147 -140 -133 -126 -119 -112 -105 -98 -91 -84 -77 -70 -63 -56 -49 -42 -35 -28 -21 21 28 35 42 49 56 63 70 77 84 91 98 105 112 119 126 133 140 147

6 -126 -120 -114 -108 -102 -96 -90 -84 -78 -72 -66 -60 -54 -48 -42 -36 -30 -24 -18 18 24 30 36 42 48 54 60 66 72 78 84 90 96 102 108 114 120 126

5 -105 -100 -95 -90 -85 -80 -75 -70 -65 -60 -55 -50 -45 -40 -35 -30 -25 -20 -15 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 105

4 -84 -80 -76 -72 -68 -64 -60 -56 -52 -48 -44 -40 -36 -32 -28 -24 -20 -16 -12 12 16 20 24 28 32 36 40 44 48 52 56 60 64 68 72 76 80 84

3 -63 -60 -57 -54 -51 -48 -45 -42 -39 -36 -33 -30 -27 -24 -21 -18 -15 -12 -9 9 12 15 18 21 24 27 30 33 36 39 42 45 48 51 54 57 60 63 Probability 2 -42 -40 -38 -36 -34 -32 -30 -28 -26 -24 -22 -20 -18 -16 -14 -12 -10 -8 -6 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42

1 -21 -20 -19 -18 -17 -16 -15 -14 -13 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21

-21 -20 -19 -18 -17 -16 -15 -14 -13 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21

Consequence

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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999

4 Recommended Management and Mitigation Measures The CS of an identified heritage resource informs the level of the identified potential impact to that resource which in turn informs the recommended management and mitigation requirements. Table 4-1 presents an overview of the minimum recommended mitigation requirements considering the CS of the heritage resource. Table 4-1: Minimum Recommended Management or Mitigation Requirements Considering CS

Determined CS Minimum Management / Mitigation Requirements4

Negligible Sufficiently recorded through assessment, no mitigation required

Resource must be recorded before destruction, may include detailed Low mapping or surface sampling

Mitigation of the resource to include detailed recording and limited test Medium excavations

Project design must aim to minimise impacts; Medium-High Mitigation of resources to include extensive sampling through test excavations and analysis

Project design must aim to avoid impacts; High Cultural heritage resource to be partially conserved, must be managed by way of Conservation Management Plan

Project design must be amended to avoid all impacts; Very High Cultural heritage resources to be conserved in entirety and conserved and managed by way of Conservation Management Plan

The desired outcome of an impact assessment is the avoidance of all negative impacts and enhancement of positive ones. While this is not always possible, the recommended management or mitigation measures must be reasonable and feasible taking into consideration the determined CS and nature of the Project. Two categories of impact management options are considered: avoidance and mitigation. Avoidance requires changes or amendments to Project design, planning and siting of infrastructure to avoid physical impacts on heritage resources. It is the preferred option, especially where cultural heritage resources with high – very-high CS will be impacted.

4 Based on minimum requirements encapsulated in guidelines developed by SAHRA

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Methodology Statement Cultural Significance, Field Rating and Impact Assessment ZZZ9999

Mitigation of cultural heritage resources may be necessary where avoidance is not possible, thus resulting in partial or complete changes (including destruction) to a resource. Such resources need to be protected until they are fully recorded, documented and researched before any negative impact occurs. Options for mitigating a negative impact can include minimization, offsets, and compensation. Examples of mitigation measures specific to cultural heritage include: ■ Intensive detailed recording of sites through various non-intrusive techniques to create a documentary record of the site – “preservation by record”; and ■ Intrusive recording and sampling such as shovel test pits (STPs) and excavations, relocation (usually burial grounds and graves, but certain types of sites may be relocated), restoration and alteration. Any form of intrusive mitigation is normally a regulated permitted activity for which permits5 need to be issued by the Heritage Resource Authorities (HRAs). Such mitigation may result in a reassessment of the value of a cultural heritage resource that could require conservation measures to be implemented. Alternatively, an application for a destruction permit may be made if the resource has been sufficiently sampled.

Where resources have negligible CS, the specialist may recommend that no further mitigation is required, and the site may be destroyed where authorised. Community consultation is an integral activity to all above-mentioned avoidance and mitigation measures.

5 Permit application processes must comply with the relevant Section of the NHRA and applicable Chapter(s) of the NHRA Regulations, 2000 (Government Notice Regulation [GN R] 548) and must be issued by SAHRA or the Provincial Heritage Resources Authority (PHRA) as is applicable.

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