Heritage Cases

You comment in terms of the heritage and palaeontology of the Draft EMPR is requested. Kindly note that the MTHS project is a SIP project and Mulilo Total Hydra Storage (Pty) Ltd is a Preferred Bidder. In the attached Heritage Statement Letter,, Dr Jayson Orton confirmed the following:- • The final layout for the three solar energy facilities forming part of the Mulilo Total Hydra Storage (MTHS) has been considered. The three facilities making up the MTHS are known as: o Badenhorst Solar PV2 o Badenhorst Dam Solar PV3 o Mulilo De Aar PV. • The layout of the 75MW Badenhorst PV2 project area avoids all known heritage resources and there are no further heritage concerns. General conditions are however applicable : • Non-compliance with section of the NHRA is an offense in terms of section 51(1)e of the NHRA and item 5 of the Schedule. • If any evidence of archaeological sites or remains (e.g. remnants of stone-made structures, indigenous ceramics, bones, stone artefacts, ostrich eggshell fragments, charcoal and ash concentrations), fossils or other categories of heritage resources are found during the proposed development, SAHRA APM Unit (Natasha Higgitt/Phillip Hine 021 462 5402) must be alerted as per section 35(3) of the NHRA. 38(4)c(ii). • If unmarked human burials are uncovered, the SAHRA Burial Grounds and Graves (BGG) Unit (Thingahangwi Tshivhase/Mimi Seetelo 012 320 8490), must be alerted immediately as per section 36(6) of the NHRA. Palaeontology Dr John Almond confirmed the following:- • The fossil heritage of the proposed solar facility developments are confined to the development footprint and are only anticipated during the construction phase. • In view of the generally LOW palaeontological heritage sensitivity of the study area, as far as fossil heritage is concerned, the impact significance of the proposed solar PV facilities is LOW (with or without mitigation). Note that the PIA Statement Letter attached was compiled for the purpose of the 75MW Badenhorst PV2 BESS EA Amendment Application, but it also confirms the general palaeontological significance of the study area. Dr Almond also undertook the paleontological studies for the Application for Environmental Authorisation in July 2013. In this study he concluded the following :- Potential impacts of the proposed solar facility developments on fossil heritage are confined to the development footprint and are only anticipated during the construction phase. As far as fossil heritage is concerned, their impact significance is considered to be LOW for the following reasons: • The Karoo Supergroup bedrocks here are deeply weathered, locally calcretised and baked, and for the most part only sparsely fossiliferous; • The development footprints for the proposed PV facilities are small and largely underlain by superficial deposits of low palaeontological sensitivity; • Significant fossil material (e.g. fossil wood, vertebrate remains) at or near surface level is most likely only very sparsely distributed within the study area; and • Extensive, deep bedrock excavations are not envisaged during the construction phase.