HERITAGE IMPACT ASSESSMENT In terms of Section 38(8) of the NHRA for the Proposed Kuruman Wind Energy Facility (Phase 1 and 2) including grid connection infrastructure, Kuruman, Northern Cape Prepared by Jenna Lavin and Nic Wiltshire With Jonathan Kaplan (ACRM) and Dr John Almond (Natura Viva cc) In Association with the CSIR July 2018 THE INDEPENDENT PERSON WHO COMPILED A SPECIALIST REPORT OR UNDERTOOK A SPECIALIST PROCESS I Jenna Lavin, as the appointed independent specialist hereby declare that I: • act/ed as the independent specialist in this application; • regard the information contained in this report as it relates to my specialist input/study to be true and correct, and • do not have and will not have any financial interest in the undertaking of the activity, other than remuneration for work performed in terms of the NEMA, the Environmental Impact Assessment Regulations, 2010 and any specific environmental management Act; • have and will not have no vested interest in the proposed activity proceeding; • have disclosed, to the applicant, EAP and competent authority, any material information that have or may have the potential to influence the decision of the competent authority or the objectivity of any report, plan or document required in terms of the NEMA, the Environmental Impact Assessment Regulations, 2010 and any specific environmental management Act; • am fully aware of and meet the responsibilities in terms of NEMA, the Environmental Impact Assessment Regulations, 2010 (specifically in terms of regulation 17 of GN No. R. 543) and any specific environmental management Act, and that failure to comply with these requirements may constitute and result in disqualification; • have ensured that information containing all relevant facts in respect of the specialist input/study was distributed or made available to interested and affected parties and the public and that participation by interested and affected parties was facilitated in such a manner that all interested and affected parties were provided with a reasonable opportunity to participate and to provide comments on the specialist input/study; • have ensured that the comments of all interested and affected parties on the specialist input/study were considered, recorded and submitted to the competent authority in respect of the application; • have ensured that the names of all interested and affected parties that participated in terms of the specialist input/study were recorded in the register of interested and affected parties who participated in the public participation process; • have provided the competent authority with access to all information at my disposal regarding the application, whether such information is favourable to the applicant or not; and • am aware that a false declaration is an offence in terms of regulation 71 of GN No. R. 543. Signature of the specialist CTS Heritage Name of company 20 July 2018 Date 1 CTS Heritage 34 Harries Street, Plumstead, Cape Town, 7800 Tel:​ (087) 073 5739 ​Email:​ [email protected] ​Web:​ www.ctsheritage.com EXECUTIVE SUMMARY Mulilo Renewable Project Developments (Pty) Ltd (hereafter, “Mulilo”) appointed the Council of Scientific and Industrial Research (hereafter, “CSIR”). Mulilo has proposed to build the Kuruman Wind Energy Facility (WEF) in two phases (1&2). This assessment is for Phases 1 and 2 of this project, as well as the proposed 132kV powerline. The number of turbines to be completed in Phase 1 is 47 and Phase 2 is 52. Each turbine has a maximum output of 4.5MW, blade height of 140m and blade length of 80m. Foundations will be excavated to a depth of 3m. Additional infrastructure assessed for the EIA will include 5m wide connecting roads and widening of existing roads to 8m. New roads constructed will connect all turbines. The WEF will also be connected to the grid via two 132kV overhead powerlines to Kuruman (Segame Substation, 10km in length) and Kathu (Ferrum Substation, 50km in length). Proposed WEF The study site for the proposed Phase 1 and 2 Kuruman WEF (i.e. turbine location sites, access roads, substations, laydown areas) is not a sensitive archaeological landscape. A limited number of stone implements (isolated and dispersed scatters of Later Stone Age tools including retouched and utilized flakes, chunks, and a few cores in locally available banded ironstone), occur on some of the high hill top sites and access roads. Archaeological artefacts are located among extensive scatters of ironstone gravels which are ubiquitous in the surrounding area. No settlement sites, quarry sites, or evidence of human occupation were identified. Banded ironstone is a ready source of raw material across the entire study area. The hilltop sites are not conducive to pre-colonial settlement due to their high elevation, lack of caves as well as their isolated, exposed, cold and windy nature. The proposed WEF substations and laydown areas do not constitute a sensitive archaeological landscape. All comprise level sites covered in knee high dry grass on red sands. Given the low overall low palaeosensitivity of the proposed footprint, it is concluded that in terms of palaeontological heritage resources the impact significance of the Kuruman WEF Phase 1 an 2 is ​low (​negative​), both before and after mitigation. This assessment applies to the construction phase and to all relevant components of the WEF infrastructure (​e.g. wind turbines, internal and external access roads, underground cabling, on-site substation and construction yards). Significant impacts during the operational and de-commissioning phases are not anticipated. None of the fossil sites identified fall inside the WEF development footprint and no specialist palaeontological mitigation is therefore proposed here. Small stromatolite-rich outcrop areas of Campbell Rand carbonates to the east of the WEF footprint (areas outlined in red in Figures 8a, b and c) should be designated as No-Go Areas and protected from any disturbance or development. Proposed Powerline Route The proposed powerline route is not a sensitive archaeological landscape, despite it crossing several eco-zones. Long stretches of the route, for example, from Bothaskop till the district gravel road, cross mostly flat lands covered in knee high dry grasses and dense Acacia thicket vegetation on a substrate of loose, red sands. Extensive scatters and patches of ironstone gravels occur in places, where only a few isolated tools were noted, but no settlement or occupation sites were located. Indications are that these tools represent mostly discarded flakes and/or flake debris. The route, from the district gravel road, over the hilltops to Bramcote Farm is also not a sensitive archaeological landscape. Most of the route passes through Woodstock Farm towards the Eskom substation at Kuruman. It crosses flat lands covered in tall dry grasses, with small pockets of dense thicket (Acacia) vegetation (closer to Kuruman), on a substrate of red sands with virtually no surface stone occurring. However, patches and scatters of banded ironstone do occur in places, where a few isolated tools in banded iron stone were identified, however these are mostly discarded flakes and flake debris. Some of these occurrences are located outside of the study area, and were not given GPS locations. 2 CTS Heritage 34 Harries Street, Plumstead, Cape Town, 7800 Tel:​ (087) 073 5739 ​Email:​ [email protected] ​Web:​ www.ctsheritage.com It is interesting to note that fine grained CCS / translucent chert flakes were also noted in the powerline route between Hartlands Farm and the Kuruman Eskom substation, and on Bothaskop (located outside of the study area). In terms of palaeontological heritage resources, the impact significance of the Kuruman WEF 132 kV grid connection is low (negative), both before and after mitigation. This assessment applies to both 132 kV grid connection options under consideration and is based on (1) the low overall low palaeosensitivity of the 132 kV grid connection study region (including both corridor alternatives) as well as (2) the small footprint of the individual electrical pylon footings and associated service roads (i.e. small volume of bedrock excavations or surface clearance entailed). There is no preference on palaeontological heritage grounds for either one of the grid connection route options. Significant impacts during the operational and de-commissioning phases of the 132 kV grid connection are not anticipated. Confidence levels for this assessment are medium, given the low levels of bedrock exposure. In the context of other alternative energy and associated powerline developments in the broader Kathu – Kuruman region, cumulative impacts posed by the Kuruman WEF 132 kV grid connection project are of low significance. Recommendations No mitigation is required prior to construction activities occurring. However, it is recommended that a Heritage Conservation Management Plan be developed for the WEF to ensure that heritage resources are continuously managed throughout the operational phase of the development. This CMP must be required as a condition of Environmental Authorisation. Rock Art - All rock art sites (Sites KUR28, KUR36, KUR37, KUR44, KUR45, KUR46 and TK1, TK3, TK4 and TK5), must be avoided and should not be visited. Location of rock art sites should not be made public. - A no-go buffer zone of 20m must be kept around each rock art site Burial Grounds and Graves - These sites must not be impacted by the proposed development (TK2A, TK7, TK8 and BR2 and BR6) - a 50m buffer