A report on a cultural heritage impact assessment for the development of a de-stoning plant at the new Denmark Colliery, close to Standerton, Mpumalanga ProvinceSummary

Archaetnos cc was requested by SRK Consulting to conduct a cultural heritage impact assessment for a proposed de-stoning plant at the New Denmark Colliery. This is between Bethal and Standerton in the Mpumalanga Province.

A survey of the available literature was undertaken in order to obtain background information regarding the area. This was followed by the field survey which was conducted according to generally accepted HIA practices, aimed at locating all possible objects, sites and features of cultural significance in the area of the proposed development.

All sites, objects features and structures identified were to be documented according to the general minimum standards accepted by the archaeological profession. Co-ordinates of individual localities were determined by means of a Global Positioning System (GPS). The information was added to photographs and the description in order to facilitate the identification of each locality.

The Terms of Reference for the survey were to:

1. Identify objects, sites, occurrences and structures of an archaeological or historical nature (cultural heritage sites) located on the property.

2. Doing a baseline and desktop assessment of the historical background of the area to be developed.

3. Assess the significance of the cultural resources in terms of their archaeological, historical, scientific, social, religious, aesthetic and tourism value.

4. Describe the possible impact of the proposed development on these cultural remains, according to a standard set of conventions.

5. Recommend suitable mitigation measures to minimize possible negative impacts on the cultural resources by the proposed development.

6. Review applicable legislative requirements.


The following conditions and assumptions have a direct bearing on the survey and the resulting report:

1. Cultural Resources are all non-physical and physical man-made occurrences, as well as natural occurrences associated with human activity.

2. The significance of the sites, structures and artifacts is determined by means of their historical, social, aesthetic, technological and scientific value.

3. Cultural significance is site-specific and relates to the content and context of the site.

4. The latitude and longitude of any archaeological or historical site or feature, is to be treated as sensitive information.

5. All recommendations are made with full cognizance of the relevant legislation.

6. It has to be mentioned that it is almost impossible to locate all the cultural resources in a given area, as it will be very time consuming. Developers should however note that the report should make it clear how to handle any other finds that might occur.


Aspects concerning the conservation of cultural resources are dealt with mainly in two acts. These are the National Heritage Resources Act (Act 25 of 1999) and the National Environmental Management Act (Act 107 of 1998).

According to the NHRA the following is protected as cultural heritage resources:

a. Archaeological artifacts, structures and sites older than 100 years

b. Ethnographic art objects (e.g. prehistoric rock art) and ethnography

c. Objects of decorative and visual arts

d. Military objects, structures and sites older than 75 years

e. Historical objects, structures and sites older than 60 years

f. Proclaimed heritage sites

g. Grave yards and graves older than 60 years

h. Meteorites and fossils

i. Objects, structures and sites or scientific or technological value.


Section 35(4) of this act deals with archaeology, palaeontology and meteorites and states that no person may, without a permit issued by the responsible heritage resources authority):

a. destroy, damage, excavate, alter, deface or otherwise disturb any archaeological or paleontological site or any meteorite;

b. destroy, damage, excavate, remove from its original position, collect or own any archaeological or paleontological material or object or any meteorite;

c. trade in, sell for private gain, export or attempt to export from the Republic any category of archaeological or paleontological material or object, or any meteorite; or

d. bring onto or use at an archaeological or paleontological site any excavation equipment or any equipment that assists in the detection or recovery of metals or archaeological and paleontological material or objects, or use such equipment for the recovery of meteorites.

e. alter or demolish any structure or part of a structure which is older than 60 years as protected.


In terms of Section 36(3) of the National Heritage Resources Act, no person may, without a permit issued by the relevant heritage resources authority:

a. destroy, damage, alter, exhume or remove from its original position of otherwise disturb the grave of a victim of conflict, or any burial ground or part thereof which contains such graves;

b. destroy, damage, alter, exhume or remove from its original position or otherwise disturb any grave or burial ground older than 60 years which is situated outside a formal cemetery administered by a local authority; or

c. bring onto or use at a burial ground or grave referred to in paragraph (a) or (b) any excavation, or any equipment which assists in the detection or recovery of metals.


The evaluation of heritage sites is done by giving a field rating of each using the following criteria:

• The unique nature of a site

• The integrity of the archaeological deposit

• The wider historic, archaeological and geographic context of the site

• The location of the site in relation to other similar sites or features

• The depth of the archaeological deposit (when it can be determined or is known)

• The preservation condition of the site

• Uniqueness of the site and

• Potential to answer present research questions.


During the survey three sites of cultural heritage significance were located. These are discussed in the report and mitigation measures are proposed. After implementation of these, the proposed development may continue.

The following is recommended:

• For site no 1 (historical farm yard) the recommendation is to leave it in situ since it lies to the south of the river where no direct impact is expected. The structures can then rather deteriorate via natural processes.

• Should this not be possible, it may be demolished as this report is seen as ample mitigation. A destruction permit for this should be obtained from The Mpumalanga PHRA.

• For site no 2 (historical farm yard) the recommendation is similar. If possible it should be left as it is to deteriorate through natural processes.

• Should this not be possible, the buildings may be demolished. Before doing so, the smaller house should however be properly documented as indicated. The destruction of site can also only be done after a destruction permit has been obtained from The Mpumalanga PHRA.

• Site 3 is a grave site. There are two options when dealing with graves. The first would be to fence it in and write a management plan for the preservation thereof. This option will come into play if there is no direct impact on the graves. It should be kept in mind that there always is a secondary impact on graves since families may not have access thereto once a mine comes into operation.

• The second option is to have the graves exhumed and the bodies reburied. This option is preferred when graves cannot be avoided by the development. Before exhumation can be done a process of social consultation is needed in order to find the associated families and obtain permission from them. For graves younger than 60 years only an undertaker is involved in the process, but for those older than 60 years or with an unknown date of death, an undertaker and archaeologist should be involved. Unknown graves are handled similarly to heritage graves.

• The graves are extremely close to the development footprint and therefore a definite impact is foreseen. Therefore option 2 is recommended. In order to be able to do this 2 the developer would have to motivate that this is the only available option.

• However option 1 would also be a viable option. It means that the site should be left in situ. It should then be fenced in and a conservation management plan for the sustainable preservation and management thereof should be drafted and implemented.

• After implementation of the mitigation measures recommended, the proposed development may continue.

• It should be noted that the subterranean presence of archaeological and/or historical sites, features or artifacts is always a distinct possibility. Care should therefore be taken when development commences that if any of these are discovered, a qualified archaeologist be called in to investigate the occurrence.


It is also important to take cognizance that it is the client’s responsibility to do the submission of this report via the SAHRIS System on the SAHRA website. No work on site may commence before receiving the necessary comments from SAHRA.


Report by

Dr. A.C. van Vollenhoven (L.AKAD.SA.)