A report relating to the heritage impact assessment (HIA) for the Exxaro Matla Colliery stooping pillars of the underground works, near Kriel in the Mpumalanga Province


Archaetnos cc was appointed was appointed by GCS to conduct a cultural heritage impact assessment (HIA) study for the Exxaro Matla Colliery Stooping Pillars of the underground works Project. The project will be an underground coal mining operation and associated infrastructure.

Thee mining right area covers approximately 22 000 ha and has been extensively mined by underground coal mining activities. The reclamation of the remaining coal reserves will utilize most of the existing current operations’ infrastructure.

The entire area was already surveyed during 2012. The latest survey served as confirmation of specific areas to be mined as well as the heritage resources found during the previous survey.

The proposed mining is planned on the following portions:
• portion 1 and 2 of the farm Uitvlugt 255 IR,
• portion 3 of the farm Strehla 261 IR,
• portion 1, 4, 5, 15, 23 and 26 of the farm Moedverloren 88 IR,
• portion 6 of the farm Weltevreden 307 IR,
• the remainder and portion 3, 5, 6, 9 and 10 of the farm Kortlaagte 67 IS,
• portion 2, 9, 12 and 14 of the farm Rietvlei 62 IR,
• portion 2, 3, 5, 6, 7, 10, 23, 29, 30 and 32 of the farm Grootpan 86 IS,
• the remainder and portion 1, 2, 3, 5 and 7 of the farm Bakenlaagte 84 IR,
• portion 22, 23, 26, 27, 52 and 53 of the farm Vierfontein 61 IS,
• the remainder and portion 1 and 5 of the farm Onverwacht 97 IS,
• portion 5 of the farm Haasfontein 85 IS,
• the remainder and portion 1 and 2 of the farm Kruisementfontein 95 IS,
• the remainder and portion 1, 2, 4 and 6 of the farm Nooitgedacht 94 IS and
• the entire farm Matla Power Station 141 IS.

The Scope and purpose for the survey were to do an archaeological and heritage survey and assessment according to generally accepted HIA practices endorsed by SAHRA and ASAPA. In the process the aim was to identify all objects, sites, occurrences and structures of an archaeological or historical nature (cultural heritage sites) located on the property and to assess the significance of these cultural resources in terms of their archaeological, historical, scientific, social, religious, aesthetic and tourism value. These were to be documented, and the possible impact of the proposed development on these was to be described. In addition suitable mitigation measures to minimize possible negative impacts on the cultural resourceswere to be proposed.

Cultural Resources are all non-physical and physical man-made occurrences, as well as natural occurrences associated with human activity and include all sites, structures and artifacts of importance. Graves and cemeteries are included in this.

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 particular case there were certain areas with dense vegetation which made archaeological visibility difficult.
In some instances gates were closed making it impossible to view certain areas.

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 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 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.

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 are made.

The evaluation of heritage sites is done by 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.
Before doing the physical survey, a survey of literature was undertaken in order to obtain background information regarding the area. This was followed by the field survey. People from local communities are also interviewed in order to obtain information relating to the surveyed area.

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

The surveyed area is mostly disturbed due to previous human activities on the site. This includes mainly agricultural activities such as ploughing and the planting of maize and other crops, as well as grazing. Certain areas are covered by grass, which were of different lengths. Some plantation areas (blue gum, poplar, wattle etc.) are also found, in certain cases reasonably inaccessible.

The Matla Power Station dominates the landscape and current mining operations and infrastructure are also to be found nearby. The topography of the area consists of rolling hills with a gentle slope. Declinations are found close to rivers. The main water source is the Riet Spruit which runs from the south-west to the north-east. A number of pans are also found.

The fieldwork undertaken during 2012 revealed thirty sites of cultural heritage significance. During the 2014 survey it was found that only fourteen remained within the area to be impacted (the stooping area). An additional site was also identified, making the total number of sites fifteen. The recommended mitigation and management measures for these are summarized as follows:

1. Sites number 15 and 16 may be re-used for offices or another appropriate purpose. However, for any changes to be made to the structures a permit needs to be issued by the Provincial Heritage Resources Agency (PHRA) of Mpumalanga. These structures should be preserved if at all possible.

2. As these buildings falls within the underground mining area, it is possible that it may be damaged during mining activities. For instance, the soil may cave in. Therefore the recommendation is that both should also be documented during a phase II investigation in order to preserve basic information. Should any damage then occur, the mine may apply for a demolition permit from the Mpumalanga PHRA.

3. Regular inspections (at least once a month) should be done by the mine to ensure immediate action if a cave-in is experienced.

4. No visible evidence of site number 30 (Battle of Bakenlaagte) was found and therefore the site cannot be preserved. It however remains an important part of the history of South Africa and should be commemorated, perhaps by placing a plaque next to the road, as close as possible to the site.

5. It is also recommended that, should any artifact related to the battle be unearthed or found during activities on site, an archaeologist should immediately be contacted to investigate the find. It is extremely important to adhere to this recommendation as this part of South Africa’s history is very fragile and needs to be documented as far as possible.

6. The threat of the ground collapsing under the heritage sites is very real, as similar in-caving as a result of mining activities have been seen throughout the survey area.

7. Graves are always given a rating of high cultural significance due to it being a sensitive matter.

8. Usually there are two options when dealing with graves. Table 1 can be used to assist in determining the risks involved with both options.

9. The first option is to leave the graves in situ. This would be possible should there be no direct impact on the graves. However, there always is a secondary impact as descendants may find it difficult to visit the site once mining has commenced. Therefore the site should be fenced in and a management plan should be written for the preservation and maintenance thereof. Such a fence should be erected at least 50 m from the perimeter of the site as blasting closer than that will definitely have a negative impact on the graves. In certain cases the blasting buffer need to be as much as 200 m as it may damage the headstones. A blasting expert should be consulted in this regard and a report be furnished to SAHRA for approval.

10. The Management Plan would entail aspects such as the fence and site management and maintenance. In addition, the plan would provide details on how it will be possible for descendants that might wish to visit the graves, when access will be granted as the mine is compelled to grant access. The fence and site will need to be managed and maintained. The management plan includes inter alia arrangements for security and safety measures. Other measures would include the preservation and
maintenance of the site where aspects such as cleaning and upkeep will be dealt with. Such a plan should be written and then monitored annually by an independent heritage specialist.

11. The plan will have to be approved by the Burial Grounds and Graves Unit (BGG) of the South African Heritage Resources Agency (SAHRA). SAHRA has specific guidelines for management plans and these will have to be followed.

12. The fencing and management plan option is recommended for all grave sites, being number 4, 10, 11, 12, 14, 17, 18, 21, 22, 23, 24 and 31.

13. The mine will have to do regular inspections at all these sites (at least once a month) and at the first sign of a possible cave-in they should immediately start liaising with SAHRA about the exhumation and relocation thereof.

14. However, should there be any danger of possible cave-in’s of these site or should the mine decide that it would be better for their operations to have these exhumed and relocated (option 2), this process should be followed. This may be allowed upon SAHRA approval and is discussed below.

15. The second option is to exhume the graves and have the bodies reburied. This usually is only allowed if there is a direct impact on the site. Such a process has to be motivated to SAHRA and permits needs to be applied for. It is a lengthy process and includes social consultation in accordance with legislation in order to obtain permission from descendants or at least proof that a concerted effort has been made to do such consultation.

16. This would mean that the mining activities could go on undisturbed.

17. Graves younger than 60 years are handled by a registered undertaker. Graves older than 60 years and those of an unknown date is regarded as heritage graves. In such a case an archaeologist is also involved in the process. Graves with an unknown date are always handled as if older than 60 years.

18. It is standard procedure in such cases to also do some test excavations as there usually are more graves than what can be seen from grave dressings and headstones.

19. Due to constraints indicated in this report it is possible that all heritage sites may not have been identified. Such sites found later on should be handled in accordance with this report which inter alia includes summoning an archaeologist to site to assess these.

20. It should be noted that the subterranean presence of archaeological and/or historical sites, features or artifacts is always a distinct possibility. This includes graves. 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.

21. It is difficult to do a sensitivity assessment of the area as heritage sites usually only covers a small amount of land. One should be on the lookout for clumps of trees or grass within ploughed fields which may indicate graves or ruins. In this area it seems as if graves were particularly found in plantations, close to houses or ruins and in wetland areas and therefore these areas will also have a high sensitivity rating. The problem is that a few graves were found inside of ploughed fields without any vegetation around it – this basically means that one can found graves anywhere. The bottom line is that the nature of heritage sites is such that predicting its locations is almost impossible.

22. Once the recommended mitigation measures have been implemented, the mining activities may continue.

Report by

Dr. A.C. van Vollenhoven (L.AKAD.SA.) Accredited member of ASAPA Accredited member of SASCH & Zurethe Collins BA, BA (Hons)