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CaseReference:
HeritageAuthority:
- SAHRA
Committee:
DecisionDate:
DecisionStatus:
CaseDiscussion:
Green Direction Sustainability Consulting (Pty) Ltd has been appointed by Shirley Hayes-IPK (Pty) Ltd (SHIP) to conduct an Environmental Authorisation Application for proposed mining activities on a portion of Plot 2100 Concordia Township in the Namaqualand District of the Northern Cape (NC30/5/1/2/2/10166MR).
A draft Environmental Impact Assessment (EIA) has been submitted in terms of the National Environmental Management Act, 1998 (NEMA) and the 2014 EIA Regulations for activities that trigger the Mineral and Petroleum Resources Development Act, 2002 (MPRDA)(As amended). The proposed activities include underground mining within the Rietberg and Homeep Mines and open pit excavations within the Jubilee mine. Associated infrastructure and activities will include waste and ROM stockpiles, tailings storage dam, processing plant, access and haul roads, powerlines, security infrastructure and dewatering of the old mines.
ASHA Consulting (Pty) Ltd has been appointed to provide heritage input into the EIA process as per section 38(3) and 38(8) of the National Heritage Resources Act, Act 25 of 1999 (NHRA) as required by section 24(4)b(iii) of NEMA.
Almond, J. E. 2020. Palaeontological Statement: Proposed Re-Opening of the Rietberg, Jubilee and Houmeep Disused Copper Mines near Concordia, Namakwaland Magisterial District, Northern Cape.
The proposed development is underlain by Precambrian metasedimentry and igneous basement rocks that do not contain fossils. The overlying Late Caenozoic superficial deposits are of low palaeosensitivity. The project footprint is small and previously disturbed and therefore the impact significance of the proposed development on palaeontological resources is considered to be very low. A Chance Finds Procedure is recommended.
Orton, J. 2020. Heritage Impact Assessment: Proposed reopening of three Copper Mines at Concordia, Namakwaland Magisterial District.
The three mines under application are over 100 years old, with both the Rietberg and Homeep Mines established in 1854, while the Jubilee Mine was established in the 1890’s. Rietberg was abandoned in 1983/84, Homeep in 1928 and Jubilee in approximately 1978. Over 200 heritage resources were identified within the proposed development area. These include burial grounds and possible graves, historical structures and middens, historical mine workings and infrastructure, historical railway infrastructure, Stone Age surface scatters, and rock shelters.
Recommendations provided in the report include the following:
- All haul roads must make use of existing roads as far as possible (including where they cross or follow the historic copper mining railway);
- All upgrades to haul roads must be centered on the existing roads as far as possible so as to minimize impacts to features located close to these roads;
- Any alteration to the overall project footprint (i.e. mine fences and haul road locations) must be subjected to further assessment as may be required;
- All surface activities must be contained within the three mine fences to avoid impacts to unsurveyed areas;
- The final layout of each of the three mines must be considered by an archaeologist or heritage consultant to determine whether any specific mitigation measures or no-go areas not anticipated in the present assessment might be required prior to construction;
- The graveyard in the Jubilee Mine (Waypoint 111) must be fenced with a 30 m buffer and declared a no-go area. A gate should be provided for potential visitors and to allow cleaning of any wind-blown litter;
- The historical stone-built mining-related structures in the Jubilee Mine must be preserved. They can be reused if required but their modification must be approved by SAHRA to ensure that their heritage significance is not diminished (this may require the services of a heritage architect);
- The stone house and threshing floor in the Houmeep Mine (Waypoint 163) must be avoided and declared a no-go area. A 30 m buffer should be imposed if possible but this is not required. The structure should not be used for mining-related activities;
- All ruins, livestock enclosures and structures related to local herder activity and hence living heritage) must be avoided as far as is possible;
- If any herder enclosures or structures will need to be removed or will be covered by mine dumps then this must be done in consultation with their owners (if traceable) or other community members;
- If any historical underground mine workings are opened then these must be inspected (insofar as it is safe to do so) for historical traces such as hand tools, mining equipment, graffiti or other features. A report including a photographic record must be submitted to SAHRA for approval prior to modification or destruction of the historical workings;
- A chance finds procedure for recording and recovering isolated fossil finds must be incorporated into the environmental management program for the project;
- If any Stone Age, historical or industrial archaeological material (e.g. stone tools, historical rubbish dumps, historic mining equipment or tools) or human burials are uncovered during the course of development then work in the immediate area should be halted. The find would need to be reported to the heritage authorities and may require inspection by an archaeologist. Such heritage is the property of the state and may require excavation and curation in an approved institution.
Final Comment
The following comments are made as a requirement in terms of section 3(4) of the NEMA Regulations and section 38(8) of the NHRA in the format provided in section 38(4) of the NHRA and must be included in the Final EMPr:
- 38(4)a – The SAHRA Archaeology, Palaeontology and Meteorites (APM) Unit and the Burial Grounds and Graves (BGG) Unit has no objections to the proposed development;
- 38(4)b – The recommendations of the specialists are supported and must be adhered to. Further additional specific conditions are provided for the development as follows:
- A 30 m no-go bufferzone must be adhered to around all identified heritage resources with a Grade 111A or higher level of significance;
- A buffer-zone of at-least 100m must be maintained around all grave-sites protected under section 36. A fence with access gate must be erected around these sites;
- Should it not be possible to avoid the identified highly significant heritage resources that are protected by section 35 of the NHRA, as stated on page 32 of the HIA, a permit in terms of section 35 of the NHRA must be applied for in order to mitigate these sites. This must be conducted prior to the construction phase
- Should it not be possible to avoid the identified burial grounds with a 100m buffer including Waypoint 111, a consultation process for a full 60 days in terms of Chapter XI of the NHRA Regulations must be conducted in order to understand the way forward regarding the preservation of the graves;
- Should relocation of the graves be found to be the way forward, a permit in terms of section 36(3) of the NHRA and Chapter IX of the NHRA Regulations must be applied for. This must be completed prior to the construction phase;
- Once the layouts of the mines are finalised, a revised HIA must be compiled by a qualified heritage practitioner that provides a site-specific impact assessment for each identified heritage resources and site-specific mitigation measures. Currently, it is not clear what the impacts to each heritage resource is, however, it is understood that the layout has not yet been finalised;
- A Heritage Management Plan (HMP) must be developed in order to manage the in-situ heritage resources and the historical mining infrastructure including the historical underground workings. This HMP must be submitted to SAHRA for review and comment prior to the commencement of the construction phase;
- All decisions regarding heritage resources protected by section 34 of the NHRA must be sought from the Northern Cape Provincial Heritage Resources Authority;
- 38(4)c(i) – 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. 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;
- 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. 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;
- 38(4)d – See section 51(1) of the NHRA;
- 38(4)e – The following conditions apply with regards to the appointment of specialists:
- i) If heritage resources are uncovered during the course of the development, a professional archaeologist or palaeontologist, depending on the nature of the finds, must be contracted as soon as possible to inspect the heritage resource. If the newly discovered heritage resources prove to be of archaeological or palaeontological significance, a Phase 2 rescue operation may be required subject to permits issued by SAHRA;
- The Final EIA and EMPr must be submitted to SAHRA for record purposes;
- The decision regarding the EA Application must be communicated to SAHRA and uploaded to the SAHRIS Case application.
OfficialDocs:
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Case 15644 - Final Comment.pdf | 112.1 KB |