A report on a cultural heritage impact assessment done for the Anglo American Platinum and African Rainbow Minerals Modikwa Platinum Mine South Shaft 2 Project, close to Burgersfort, Limpopo Province


Archaetnos cc was requested by SRK Consulting to conduct a cultural heritage impact assessment (HIA) for the proposed Anglo American Platinum and African Rainbow Minerals Modikwa Platinum Mine South Shaft 2 Project. This is close to the town of Burgersfort and Steelpoort in the Limpopo Province.

The project includes three areas on the farms Onverwacht 292 KT and Winterveld 293 KT and entails the following development:

  • A waste rock dump for the storage of waste rock generated at the South 2 Shaft (currently it is being trucked to the waste rock dump associated with the South 1 Shaft for storage and used for the construction of the South 2 Shaft terrace);
  • An ore (reef) material transfer stockpile storage facility at the existing terrace area;
  • A waste rock transfer storage facility at the existing terrace area;
  • An ore silo and overland ore conveyor (to be situated closest to Onverwacht Hill), for the transportation of ore from South 2 Shaft to South 1 Shaft via the Onverwacht Hill for further processing;
  • An additional ventilation shaft for the management of underground ventilation (on the farm Winterveld 293 KT); and
  • Sewage sludge drying beds associated with the sewage treatment plant for the treatment of sewage during the further operational phase of the South 2 South project.
  • Conservancy tank for the handling of sewage during the construction to operational phase
  • The above proposed key infrastructure will have secondary infrastructure and activities associated with it.
  • These include:
  • River diversions associated with the waste rock dump;
  • River crossings associated with the conveyor ;
  • Access roads leading to the waste rock dump and ventilation shaft;
  • Overland ore conveyor service road; and
  • Drinking (potable) water purification plant to replace the current purification system at South 2 Shaft.

The Terms of Reference for the survey were to:

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

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.

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. 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 there were certain areas where the vegetation cover was very dense which had a negative effect on archaeological visibility.


Aspects concerning the conservation of cultural resources are dealt with mainly intwo 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 National Heritage Resources 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 of 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.

The act also states that no person may, without a permit issued by the responsible heritage resources authority (national or provincial):

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.


The above mentioned may only be disturbed or moved by an archaeologist, after receiving a permit from the South African Heritage Resources Agency (SAHRA). In order to demolish such a site or structure, a destruction permit from SAHRA will also be needed.

Graves and burial grounds are divided into the following:

a. ancestral graves

b. royal graves and graves of traditional leaders

c. graves of victims of conflict

d. graves designated by the Minister

e. historical graves and cemeteries

f. 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.


All graves older than 60 years are called heritage graves and should be handled by an archaeologist. This includes archaeological graves, which are older than 100 years. Unidentified/unknown graves (which refers to date of death) are also handled as older than 60 until proven otherwise.

Human remains that are less than 60 years old are subject to provisions of the Human Tissue Act (Act 65 of 1983) and to local regulations. Exhumation of graves must conform to the standards set out in the Ordinance on Excavations (Ordinance no. 12 of 1980) (replacing the old Transvaal Ordinance no. 7 of 1925).

Permission must also be gained from the descendants (where known), the National Department of Health, Provincial Department of Health, Premier of the Province and local police. Furthermore, permission must also be gained from the various landowners (i.e. where the graves are located and where they are to be relocated) before exhumation can take place.

The National Environmental Management Act 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 be made.

Environmental management should also take the cultural and social needs of people into account. Any disturbance of landscapes and sites that constitute the nation’s cultural heritage should be avoided as far as possible and where this is not possible the disturbance should be minimized and remedied.

The field survey for the project 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. One regularly looks a bit wider than the demarcated area, as the surrounding context needs to be taken into consideration.

If required, the location/position of any site was determined by means of a Global Positioning System (GPS), while photographs were also taken where needed. The survey was undertaken by doing a physical survey via off-road vehicle and on footand covered as much as possible of the area to be studied.

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 GPS. The information was added to the description in order to facilitate the identification of each locality.

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.


Although the project area is divided into three areas, the general environmental characteristics are more or less the same. The topography of the broader geographical area wherein the surveyed area is located consists of high mountains with steep slopes. A number of rivers cut through these creating some valleys including flat level surfaces. The latter is mostly where the infrastructure will be placed.

No sites of cultural importance were identified in the project area during the survey. However, a number of sites found during previous surveys were visited. These are:

  • Sites OWR005, OWR006 and WR008-OWR012 are all of a recent historical origin. It consists of residential structures made from clay or stone.

OWR005 – 24° 40′ 07″ S 30° 07′ 42″ E – one MSA tool was found here during the current survey

OWR006 – 24° 40′ 08″ S 30° 07′ 54″ E – Nothing was found during the current survey

OWR008 – 24° 40′ 43″ S 30° 08′ 32″ E

OWR009 – 24° 40′ 57″ S 30° 08′ 24″ E

OWR010 – 24° 41′ 04″ S 30° 08′ 21″ E

OWR011 – 24° 41′ 13″ S 30° 08′ 22″ E

OWR012 – 24° 41′ 22″ S 30° 08′ 24″ E

  • Site OWR007 is graves. However nothing was found here during the current survey. The GPS coordinates provided during the previous assessments was incorrect and has now been confirmed and changed to 24 ̊ 41’ 13” S 30 ̊ 08’ 22” E.

Five new sites were however identified outside of the project area. These consist of graves and clay walls similar to those at the sites discussed above. The GPS coordinates of the site are:

New clay walled site: 24 ̊ 40’ 25” S 30 ̊ 07’ 47” E.

Graves: Site 1 – 24 ̊ 40’ 03.4S” 30 ̊ 07’ 49.76” E.

Site 2 – 24 ̊ 40’ 14.69” S 30 ̊ 07’ 40.87 E.

Site 3 – 24 ̊ 40’ 26.18 S 30 ̊ 07’ 43.77” E.

Site 4 – 24 ̊ 39’ 46.79” S 30 ̊ 07’ 57.80” E.


Some trees were identified, which are believed to be of cultural importance. Community members of the Matimatjitji community indicated that these are important as it is believed that the ancestors sleep in the large old trees. The trees mentioned were Mohluludi, Marula, Molope, Sycamore and Acacia. No specific tree were identified and in general it was said that small trees may be demolished, but large ones not.

The following is recommended:

  • No sites of heritage significance were found in any of the surveyed area. Therefore the proposed development may continue.
  • The developer needs to take note of the other sites discussed. Apart from the graves, none is regarded as being of a high cultural significance. Since it is outside of the area to be developed it should be left in situ. No specific measures are needed.
  • The grave sites (site OWR007 and sites 1-4) are of high importance. There are two possibilities of handling this.
  • The first option would be to fence the graves in and have a management plan drafted for the sustainable preservation thereof. This should be written by a heritage expert. This is recommended since it is outside of the area of direct impact.
  • However the mine should ensure that no direct impact is experience (e.g. caving in of the soil). Should any danger be posed to the graves, option 2 will have to be taken. This is to exhume the mortal remains and then to have it relocated. For this a detailed motivation will have to be written and applied for to SAHRA. If approved, the specific procedure should be followed which includes social consultation. For graves younger than 60 years only an undertaker is needed. For those older than 60 years and unknown graves an undertaker and archaeologist is needed. Permits should be obtained from the Burial Grounds and Graves unit of SAHRA. This procedure is quite lengthy and involves social consultation.
  • It is always is difficult when confronted with issues of a social, even supernatural matter. This is the case with the trees identified. Community members indicated that only the large ones are important as it is believed that the ancestors sleep in these. They indicated that the smaller ones may be demolished. However, no specific important trees were indicated and not many large ones were seen in the surveyed area. It is recommended that a fauna specialist identify any large trees of the species indicated inside of the area to be developed and that the community be consulted on these.
  • 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.

Report by

Dr. A.C. van Vollenhoven (L.AKAD.SA.) Accredited member of ASAPA Professional member of SASCH, Cherene de Bruyn (BA), BA (Hons) Archaeology and Zurethe Collins (BA), BA (Hons) Archaeology