Report on a heritage impact assessment related to the R50 realignment project near Delmas in the Mpumalanga ProvinceSummary

Archaetnos cc was requested by GCS to conduct a cultural heritage impact assessment for the R50 road alignment. This is at the Exxaro Leeuwpan Colliery, close to the town of Delmas in the Mpumalanga Province.

The proposed development impacts on the following properties: portions 1, 9 and 36 of the farm Goedgedacht 228 IR, portion 3 of Leeuwpan 246 IR, portions 2, 4, 12, 13 and 16 of Moabsvelden 248 IR, the remainder and portions 1, 2, 8, 13 and 14 of Rietkuil 249 IR, the remainder of De Denne 256 IR, the remainder of Kenbar 257 IR and portion 9 of Weltevreden 227 IR.

The development entails two new road alignments. The first is the so-called North Road and is planned as a new access road to the mine as the current one will be mined out. The second is the re-alignment of a section of the R50 provincial road, called the south road as the mining operations will also encroach on the existing road.

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. Recommend suitable measures to manage the cultural resources in future.

5. Review applicable legislative requirements.

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

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

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 and would come at a large cost. The heritage report therefore represents merely a sample of the surveyed area and of heritage resources identified there, based on experience of the location of such sites. Developers should however note that this report should make it clear how to handle any other finds that might occur. Should the archaeologists need to visit the site again, a new appointment would therefore be needed.

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 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. An Archaeological Impact Assessment (AIA) only looks at archaeological resources. Both a HIA and an AIA exclude a Palaeontological Impact Assessment (PIA) since the latter is a totally different science.1

The different phases during the HIA process are described in Appendix E. 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 length
c. Any development or other activity that will change the character of a site and exceed 5 000m2 or involve three or more existing erven or subdivisions thereof
d. Re-zoning of a site exceeding 10 000 m2
e. Any other category provided for in the regulations of SAHRA or a provincial heritage authority

Section 34 (1) of the mentioned act states that no person may demolish any structure or part thereof which is older than 60 years without a permit issued by the relevant provincial heritage resources authority.

Section 35(4) of this act deals with archaeology, palaeontology and meteorites. This may only be disturbed or moved by an archaeologist/ palaeontologist/ geologist, 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

Unidentified/unknown graves 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).

The National Environmental Management 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.

The International Finance Corporations’ performance standard for cultural heritage 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.

The following methodology has been utilized for this survey:

Survey of literature
Field survey
Oral histories

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.

A large part of the environment of the surveyed area is disturbed by recent human activities. At the North Road this mainly consist of mining activities. At the South Road the area is disturbed by farming activities, mostly agriculture.

The topography of the area is reasonably flat. The Bronkhorstspruit runs through the area from south to north, but does not seem to have much of an influence on the topography.

This geographical area is not well-known as one containing many prehistoric sites. One however has to realize that this most likely only indicates that not much research has been done here before. On the existing SAHRA Database no such sites are indicated here.

During the survey three sites of cultural heritage significance were located. Two of these are close to the South Road and one close to the North Road.

Site 1 – Grave yard

This is a single grave with a cement headstone and border. The surname on the grave is Thokazabinde and the person died in 1986.

Site 2 – Grave yard

This is a large grave yard found in close proximity to a blue gum plantation. It consists of at least 63 graves. The graves have all kinds of grave dressings or borders and headstones – cement, stone, brick and granite.

Site 3 – Grave yard

The site consists of at least 25 graves, but access to the site could not be obtained due to a high fence and locked gate. Most of the graves have cement dressings and headstones and some are stone packed.

As far as Gaps in Knowledge are concerned the biggest problem is that there is no comprehensive database with information of the history and archaeology of South Africa. The South African Heritage Resources Agency (SAHRA) has a system, called SAHRIS, where all heritage related reports are being stored. Although this does create some sort of a database it only contains information since 2012. Older information are however gradually been introduced to SAHRIS.

It is impossible to survey an entire area, especially with large developments. It would be extremely costly. Although the aim is to identify as much as possible, a heritage survey therefore always may not identify everything of heritage value in an area.

This Phase 1 heritage impact assessment needs to be approved by SAHRA which will advise regarding the way forward. It is likely that the document will be approved, meaning that the recommendations given below should be implemented.

The implementation will either result in the relocation of grave sites or in writing and implementing a management plan therefore. The latter is the most likely. Such a management plan will include the monitoring of these sites.

It is concluded that the survey of the indicated area was completed successfully. The following is recommended:

• Three sites of cultural heritage significance were identified during the survey. These are all grave sites.
• Two possibilities exist in dealing with graves:

o The first option would be to fence the graves in and have a management plan drafted for the sustainable preservation thereof. This should be compiled by a heritage expert. This usually is done when the graves are in no danger of being damaged, but where there will be a secondary impact due to the activities of the development.

o The second option is to exhume the mortal remains and then to have it relocated. This usually is done when the graves are in the area to be directly affected by the development. For this a 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.
• In the case of site no. 2, the graves will not be impacted on directly by the development (South Road). Since there always is a secondary impact due to the activities on site, Option 1 is recommended. However, this site may be relocated should that be the only solution, provided that the correct procedures are followed.

• It is very likely that sites no. 1 (South Road) and 3 (North Road) will be impacted on directly. If at all possible, the proposed routes for the roads should be changed so that a buffer zone of at least 20 m is created. In this case Option 1 should be implemented. However, if not possible to change the plans, Option 2 may be implemented. This has to be motivated to the Burial Grounds and Graves Unit (BGG) of SAHRA.
• It is extremely important that the management plans for these sites be drafted as there will be a definite secondary impact on this. In fact, site no. 3 has already been impacted on by mine dust and this needs to be rectified.

• In cases where grave sites are already fenced in these will need to be maintained.

• After implementation of the mitigation measures indicated, the development may continue. Proof of implementation will have to be provided to SAHRA.

• It should be noted that the subterranean presence of archaeological and/or historical sites, features or artifacts is always a distinct possibility. The state of the environment also makes it possible that not all sites were identified. 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 and adapt this report.

• 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.)