A report on a basic cultural heritage assessment for the Witkop Exploration and Mining Project, Free State Province


Archaetnos cc was requested by GCS to conduct a basic heritage assessment for
the proposed Witkop Exploration and Mining Project. The project is planned on the
farm Mara A no 854 and portion 1 and the remainder of the farm Verheugd no 851 in
the Fezile Dabi District in the Free State Province. The report is done for a mining
right application and associated environmental authorization in terms of the MPRDA,

The project entails a coal mining operation by means of opencast mining method.
The area that was assessed forms part of a much larger development and apart from
opencast mining in the east of the surveyed area, no other mining or infrastructure is
planned here.


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 (see
Appendix A).
2. Study background information on 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 (see Appendix B).
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.


1. Cultural Resources are all non-physical and physical man-made occurrences,
as well as natural occurrences associated with human activity. These include
all sites, structure and artifacts of importance, either individually or in groups,
in the history, architecture and archaeology of human (cultural) development.
Graves and cemeteries are included in this.
2. The significance of the sites, structures and artifacts is determined by means
of their historical, social, aesthetic, technological and scientific value in
relation to their uniqueness, condition of preservation and research potential.
The various aspects are not mutually exclusive, and the evaluation of any site
is done with reference to any number of these aspects.
3. Cultural significance is site-specific and relates to the content and context of
the site. Sites regarded as having low cultural significance have already been
recorded in full and require no further mitigation. Sites with medium cultural
significance may or may not require mitigation depending on other factors
such as the significance of impact on the site. Sites with a high cultural
significance require further mitigation.
4. The latitude and longitude of any archaeological or historical site or feature, is
to be treated as sensitive information by the developer and should not be
disclosed to members of the public.
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. In this case certain areas within the surveyed
site were densely vegetated which affected archaeological visibility.


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).

The National Heritage Resources Act

According to the above-mentioned act 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.

A Heritage Impact Assessment (HIA) is the process to be followed in order to
determine whether any heritage resources are located within the area to be
developed as well as the possible impact of the proposed development thereon. An
Archaeological Impact Assessment only looks at archaeological resources. An HIA
must be done under the following circumstances:

a. The construction of a linear development (road, wall, power line canal
etc.) exceeding 300m in length
b. The construction of a bridge or similar structure exceeding 50m in
c. Any development or other activity that will change the character of a
site and exceed 5 000m or involve three or more existing erven or
subdivisions thereof
d. Re-zoning of a site exceeding 10 000 m
e. Any other category provided for in the regulations of SAHRA or a
provincial heritage authority

Human remains

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;
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 National Environmental Management Act

This act (Act 107 of 1998) states that a survey and evaluation of cultural resources
must be done in areas where development projects, that will change the face of the
environment, will be undertaken. The impact of the development on these resources
should be determined and proposals for the mitigation thereof are made.


This standard recognizes the importance of cultural heritage for current and future
generations. It aims to ensure that clients protect cultural heritage in the course of
their project activities.


A survey of literature was undertaken in order to obtain background information
regarding the area.

The field survey was conducted according to generally accepted HIA practices and
was aimed at locating all possible objects, sites and features of cultural significance
in the area of proposed development.

All sites, objects features and structures identified were documented according to the
general minimum standards accepted by the archaeological profession. Co-ordinates
of individual localities were determined by means of the Global Positioning System

Evaluation of Heritage sites

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.


Unfortunately there is limited information available on the historical and prehistoric
sites in the Viljoenskroon area. The area is mostly terra incognito as far as heritage
sites are concerned, due to a lack of research.


The six sites of cultural heritage importance that were identified all date to the
Historical Age. As indicated there always is a possibility that some sites may have
been missed. In such a case it should be handled in accordance with the
recommendations in this report.


Please see Tables in text.


The following is recommended:

  • Site no 1 (historical farm yard) should be mitigated as it lies right within the area to be mined. This would entail a comprehensive photographic documentation and making line drawings thereof.
  • After mitigation, a destruction permit should be obtained from the PHRA of the Free State after which it may be demolished.
  • Site no 2 (graves) should also be mitigated as it falls within the mining area. This would entail the exhumation and reburial in accordance with the SAHRA regulations and other applicable legislation mentioned above.
  • Site no 3 and 5 (graves) falls outside of the area of direct impact. It should however be mitigated by fencing it in and having a management plan drawn up for the sustainable preservation thereof. Such a plan should be drafted by a heritage specialist and approved by SAHRA.
  • Site no 4 and 6 (farm yards) have been documented sufficiently by this report. It may be demolished, but only after receiving permission from the PHRA of the Free State. However, the structures may also be left as it is to deteriorate naturally.
  • 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

Report by

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