Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province Heritage Impact Assessment Project Number: LEA5514 Prepared for: Limpopo Economic Development Agency July 2019 _______________________________________________________________________________________ Digby Wells and Associates (South Africa) (Pty) Ltd Co. Reg. No. 2010/008577/07. Turnberry Office Park, 48 Grosvenor Road, Bryanston, 2191. Private Bag X10046, Randburg, 2125, South Africa Tel: +27 11 789 9495, Fax: +27 11 069 6801, [email protected], www.digbywells.com _______________________________________________________________________________________ Directors: GE Trusler (C.E.O), LF Stevens, J Leaver (Chairman)*, NA Mehlomakulu*, DJ Otto *Non-Executive _______________________________________________________________________________________ This document has been prepared by Digby Wells Environmental. Report Type: Heritage Impact Assessment Environmental Authorisation for the proposed Musina- Project Name: Makhado Special Economic Zone Development Project, Limpopo Province Project Code: LEA5514 Name Responsibility Signature Date Shannon Hardwick Junior Heritage Resources HIA Compilation Management Consultant ASAPA Member: 451 July 2019 Justin du Piesanie Divisional Manager: Social and Technical Review Heritage Services ASAPA Member 270 This report is provided solely for the purposes set out in it and may not, in whole or in part, be used for any other purpose without Digby Wells Environmental prior written consent. Digby Wells Environmental i Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514 DECLARATION OF INDEPENDENCE Digby Wells and Associates (South Africa) (Pty) Ltd Contact Person: Shannon Hardwick Digby Wells House Tel: 011 789 9495 48 Grosvenor Road Fax: 011 789 9498 Turnberry Office Park, Bryanston E-mail: [email protected] 2191 I, Shannon Hardwick as duly authorised representative of Digby Wells and Associates (South Africa) (Pty) Ltd., hereby confirm my independence (as well as that of Digby Wells and Associates (South Africa) (Pty) Ltd.) and declare that neither I nor Digby Wells and Associates (South Africa) (Pty) Ltd. have any interest, be it business, financial, personal or other, in any proposed activity, application or appeal in respect of the Limpopo Economic Development Agency, other than fair remuneration for work performed, specifically in connection with the Heritage Resources Management (HRM) Process for the proposed Musina-Makhado Special Economic Development Zone Development Project, Limpopo Province. Full Name: Shannon Hardwick Title/ Position: Heritage Resources Management Consultant Qualification(s): MSc Experience (Years): 2 years Registration(s): Association of Southern African Professional Archaeologists (ASAPA) Digby Wells Environmental ii Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514 DECLARATION OF INDEPENDENCE Digby Wells and Associates (South Africa) (Pty) Ltd Contact Person: Justin du Piesanie Digby Wells House Tel: 011 789 9495 48 Grosvenor Road Fax: 011 789 9498 Turnberry Office Park, Bryanston E-mail: [email protected] 2191 I, Justin du Piesanie as duly authorised representative of Digby Wells and Associates (South Africa) (Pty) Ltd., hereby confirm my independence (as well as that of Digby Wells and Associates (South Africa) (Pty) Ltd.) and declare that neither I nor Digby Wells and Associates (South Africa) (Pty) Ltd. have any interest, be it business, financial, personal or other, in any proposed activity, application or appeal in respect of the Limpopo Economic Development Agency, other than fair remuneration for work performed, specifically in connection with the Heritage Resources Management (HRM) Process for the proposed Musina-Makhado Special Economic Development Zone Development Project, Limpopo Province. Full Name: Justin du Piesanie Title/ Position: Divisional Manager: Social and Heritage Services Qualification(s): MSc Experience (Years): 12 years Association of Southern African Professional Archaeologists (ASAPA) Registration(s): International Council on Monuments and Sites (ICOMOS) South Africa International Association for Impact Assessment South Africa (IAIAsa) Digby Wells Environmental iii Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514 EXECUTIVE SUMMARY The Limpopo Economic Development Agency (LEDA) is proposing to develop a Special Economic Zone (SEZ) which spans across parts of both the Musina and Makhdo Local Municipalities of the Limpopo Province (“the Project”). The Project is adjacent to the National Route 1 (“N1) highway and includes eleven plants and ancillary infrastructure associated with the metallurgical and mineral beneficiation value chain. The Project requires Environmental Authorisation (EA) through an Environmental Impact Assessment (EIA) process, to comply with the National Environmental Management Act, 1999 (Act No. 107 of 1998) (NEMA). To this end, LEDA appointed Delta Built Environment Consultants (Pty) Ltd (hereinafter Delta BEC) to undertake the required EIA process. LEDA subsequently advertised tenders for other consultancies to undertake specialist studies in support of the EIA process. LEDA appointed Digby Wells Environmental (hereinafter Digby Wells) to undertake the Heritage Resources Management (HRM) process, inclusive of a Palaeontological Impact Assessment (PIA) (refer to Appendix C). Digby Wells undertook the HRM process in compliance with Section 38 of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA). This report constitutes the Heritage Impact Assessment (HIA) report for submission to the South African Heritage Resources Agency (SAHRA) and the Limpopo Heritage Resources Authority (LIHRA). Through an understanding of various heritage resources distribution within the site-specific study area, the statement of Cultural Significance (CS) demonstrates an average low significance rating for the defined cultural landscape. This is summarised in the table below. The infrastructure design and site layout has not been finalised at the time of assessment and will be, in part, informed by the outcomes of this assessment. It is therefore anticipated that all heritage resources will be affected by the Project. The final table below presents a summary of the impact assessment. The preceding table presents an overview of the potential risks to unidentified heritage resources within the Project area. To mitigate against the identified impacts against cultural and fossil heritage resources, Digby Wells recommends: ■ LEDA amends the infrastructure design where possible to avoid identified heritage resources of significance within the Project area and incorporate a no-go buffer zone of 50 m between the heritage resources and Project activities. Digby Wells acknowledges that it may not be feasible to avoid all the identified heritage resources; ■ Where identified heritage resources are avoided, LEDA must develop and implement a Conservation Management Plan (CMP) to manage conserved heritage resource. The CMP must include any applicable mitigation measures, management strategies and proposed monitoring schedules and outline the roles and responsibilities of those involved. This document must be submitted to the Heritage Resource Authorities (HRAs) for approval prior to implementation; Digby Wells Environmental iv Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514 ■ LEDA amends the Project design to avoid negative impacts to the built heritage resources and, where possible, conserve the resources through adaptive reuse of the structures. This will require a permit issued in terms of Section 34 of the NHRA and Chapter III of the NHRA Regulations, 2000 (Government Notice Regulation [GN R] 548); ■ Where adaptive reuse of the structures is not feasible or desirable, LEDA must complete a destruction permit application process in accordance with Section 34 of the NHRA and Chapter III of the NHRA Regulations; ■ Where burial grounds and graves will be impacted upon by the proposed infrastructure, LEDA must undertake a GRP in accordance with Section 36 of the NHRA and Chapter IX and XI of the NHRA Regulations; ■ Where archaeological sites will be impacted upon by the proposed infrastructure, LEDA must record the sites in detail in accordance with Section 35 of the NHRA and Chapter IV of the NHRA Regulations; ■ A Project-specific Chance Finds Protocol (CFP) must be developed and approved by the HRAs prior to the commencement of the construction of Project-related infrastructure; and ■ The Project-specific Fossil Finds Protocol (FFP) must be approved prior to the commencement of the construction phase of the Project (refer to Appendix A of the PIA report). Digby Wells Environmental v Heritage Impact Assessment Environmental Authorisation for the proposed Musina-Makhado Special Economic Zone Development Project, Limpopo Province LEA5514 Summary of the CS of Identified Heritage Resources Resource ID Description CS INTEGRITY Geological strata with Lithologies of the Karoo Supergroup 4 Very High palaeontological sensitivity STE-002 Historical structure 3 Low STE-001 Historical structures