Archaetnos cc was requested by Bonile Health and Environmental Consultants to conduct a cultural heritage impact assessment (HIA) for the proposed Ntabankulu Agro Processing Hub Development. This is close to Ntabankulu in the Eastern Cape Province.

The study is done as part of a Basic Assessment process. The client indicated the areas to be surveyed and the survey was confined to these. It was done via foot.

The methodology for the study includes a survey of literature and a field survey. The latter 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.

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 foot and covered as much as possible of the area to be studied. Certain factors, such as accessibility, density of vegetation, etc. may however influence the coverage.

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.

During the survey five sites of cultural heritage significance were identified. Mitigation measures are proposed. After the implementation of these, the proposed development may continue.

The following is recommended:


  • Development may continue at the following development sites, since nothing of cultural importance was identified here: Piggery site 1, Poultry site 1 and the Abattoir and Meat Processing Plant.
  • For the above this report is seen as ample documentation.
  • Three grave yards were found during the survey. These are sites no. 1 and 3 (at Piggery site 2) and site 5 (at Piggery site 3). Graves are always regarded as having a high cultural significance. The field rating thereof is Local Grade III B. It should be included in the heritage register but may be mitigated.
  • Two possibilities exist. 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 usually is done when the graves are in no danger of being damaged, but where there will be a secondary impact due to the development activities.
  • 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 activities. 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.
  • The type of development makes it possible to keep the graves in situ. It means that Option 1 can be implemented. A buffer zone of at least 20 m is recommended, but should the graves be properly fenced, this may be less.
  • Site no. 5 is already fenced, and the developer just needs to ensure that there is no impact. Both sites 1 and 3 needs to be fenced in and a CMP drafted. This will ensure the sustainable utilisation and preservation of the sites.
  • At the Piggery site 2 some Late Iron Age/ Historical remains were identified. The closest of these features lies approximately 100 m from the development. It should therefore be left in situ, but it would be good to demarcate the site (for instance with danger tape) during construction to ensure that it is not impacted on.
  • At the Piggery site 3 another large Late Iron Age/ Historical site was identified. Although some of the features lies outside of the development area, it is mostly located inside. It will be extremely difficult not to impact thereon.
  • The site may however be mitigated. It should therefore be documented. This documentation includes doing test excavations and drawing a site map. After mitigation, the site may be demolished.


  • The development may only continue after receiving the necessary comments from the BGG Unit of SAHRA and the North-West Provincial Heritage Resources Authority and implementing their decision.
  • It should be noted that the subterranean presence of archaeological and/or historical sites, features or artifacts is always a distinct possibility. It may only become known later on. Therefore, operating controls and monitoring should be introduced, aimed at the possible unearthing of such features. 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 to the relevant Heritage Resources Agency. No work on site may commence before receiving the necessary comments from them.

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