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HeritageAuthority:
- SAHRA
DecisionStatus:
CaseDiscussion:
Christine Havenga & Associates in consultation with Urban Design Services and Viridian Consulting Landscape Architects has been appointed by Frogfoot Networks (Pty) Ltd to conduct a Heritage Impact Assessment (HIA) as part of an application in terms of section 38(1) of the National Heritage Resources Act, Act 25 of 1999 (NHRA) for the proposed fibre network system in the Sol Plaatje Municipal Area, Kimberley, Northern Cape Province.
The proposed fibre network will be installed in eight (8) sectors within the city and will include activities such as conventional trenching with backfilling. Aerial fibre will also be installed with associated activities such as tree and bush cutting, excavation of pole holes, and hauling of optical fibre cable. It is important to note that all activities will occur within the sidewalk section of the municipal road reserve.
Havenga, C; Berman, A and Brett, R. 2021. Heritage Impact Assessment: Deployment of a Fibre Network within the Sol Plaatje Municipal Area.
It is noted that not all individual heritage resources within the study area could be surveyed in its entirety due to the scale of the study, rather the overall cultural landscape/streetscape would be assessed.
Various heritage resources are located within the development footprint. These include two declared heritage areas in terms of section 31 of the NHRA i.e. Belgravia and Memorial Road area. These declared areas include several individual heritage resources such as the Honoured Dead Memorial Provincial Heritage Site, and the Alexander McGregor Memorial Museum Provincial Heritage Site. Other heritage resources include heritage/champion trees, historical curb stones and roadside monuments.
It is noted that the Sol Plaatje Draft Spatial Development Framework 2018- 2023 was discussed in the HIA. The dSDF notes the heritage conservation worthy areas and states that the integration of information and communication technologies within the city forms part of the smart city vision. The fibre optic network would be an integral step in achieving this goal, while the 200 Local Economic Development Strategy stressed the important role heritage plays in the tourism economy of the area.
The Visual Impact Assessment (VIA) was conducted in areas where the aerial fibre would be installed which does not include sensitive heritage areas and is more modern. There are some areas where heritage is located however, not all heritage resources were identified. The installation will include holes for the poles and braces with fibre cables strung between. While some visual impact will be unavoidable, mature trees and tree lanes do well to obscure the visual impact to pedestrians and drivers. The deployment of aerial fibre will not negatively affect the heritage significance of the areas assessed as part of the VIA.
The comments and responses provided during the Public Participation Period are noted. SAHRA agrees with the response regarding micro-trenching as part of the development. The municipality will not allow it and provides a sound reason for not supporting it, and therefore SAHRA has no mandate to enforce micro-trenching.
Recommendations provided in the report include the following:
- No aerial fibre should be allowed within the declared historical areas of Belgravia, Memorial Park and Klisser;
- Alternative pole structures should be investigated on street corner/intersections which are visually intrusive;
- Poles should be erected on erf corners and not directly in front of dwelling houses or other structures;
- Where possible poles should be positioned in such a manner that the mature trees and tree lanes can absorb its visual impact on the streetscape. The excavations for poles should, however, comply with the Tree Protection Guideline for Construction, Excavation & Trenching for Aerial and Underground Fibre Optic Cabling (Annexure 5) and Frogfoot Draft FTTH Aerial Line Cable Specifications (Annexure 6) to protect the mature trees in these areas;
- No poles should be erected directly in front of local heritage resources such as open spaces, churches, schools, monuments, cemeteries and other significant buildings or structures. Poles should be erected on the erf corners and when these street fronts are too long to accommodate the standard cable span, conventional trenching would be the more desirable option of fibre deployment;
- Certain mitigating measures need to be complied with to protect the root systems of the mature trees which are also an important heritage resource in these areas;
- The historic pavement structures should also not be damaged and all excavations should be underneath the historic curb stones;
- Aerial fibre in the remainder of the study area can thus be supported subject to certain mitigation measures to further lessen the visual impact thereof, especially on street corners and intersections as well as on erven with longer street fronts such as open spaces, community buildings as well as other individual sites with heritage significance. In these areas the trees and tree lanes are considered to be the more important heritage resource and conventional trenching which could damage the root systems of the mature trees is thus the less desirable option;
- Archaeological monitoring of all excavation activities by a suitably qualified and registered archaeologist;
- A Close-Up Report be prepared by Frogfoot Networks within 30 days of completion confirming compliance with the recommendations of the Heritage Impact Assessment;
- Although fibre deployment by means of micro-trenching would be the most desirable option from a heritage point of view, this is not being allowed by the Sol Plaatje Municipality in terms of their Wayleave Approvals. It is thus recommended that the most area appropriate deployment of fibre as per the recommendations of the Heritage Impact Assessment be allowed to continue, subject to the implementation of the proposed mitigation measures due to the important economic advantages which the deployment of a fibre network would have for residents of the Sol Plaatje Municipal area.
Interim Comment
While SAHRA is not opposed to the development, as it is clear that a fibre network would be beneficial to the residents and business of the Sol Plaatje Municipality, the SAHRA Archaeology, Palaeontology and Meteorites (APM) Unit cannot accept the submitted HIA as section 38(3) of the NHRA has not been fully complied with. The reasons for this will be discussed below:
- There are various gaps in the requirements as per section 38(3)a with regards to the identification and mapping of heritage resources in the area to be affected. It is noted several times in the report that it is the responsibility of the relevant heritage authority to do a detailed heritage audit and to prepare a heritage register. While SAHRA notes the scale of the project and the woks to be completed, in order to provide clear and concise recommendations for the management and mitigation of negative impacts to heritage resources, every heritage resource to be impacted must be listed, their significance noted and the impact to these resources discussed. This is the responsibility of the specialist appointed to conduct the HIA. Many of the historical buildings themselves will be indirectly impacted such as a visual impact, however, the historical curb stones, heritage trees and other features such as heritage boundary walls with decorative details and gates, roadside memorials i.e. corner of Lennox and the N12 will be directly impacted. These features must be mapped. SAHRA recommends producing a map per sector as described in the HIA with a corresponding list with description, photograph, significance and impacted assessment per resource including areas and streetscapes with the corresponding mitigation measures to be implemented to ensure continuous compliance throughout the rollout of the fibre network;
- Additionally, Kimberley is known to contain archaeological resources on a sub-surface level. During the Siege of Kimberley, various structures were built in some areas close to the proposed development area such as the McGregor Museum (https://museumsnc.co.za/new_site/satellites/mcgregor-museum2/). There are archaeologically sensitive areas across the development area that must be assessed and appropriate mitigation measures recommended. It must be noted that a discussion regarding section 35 of the NHRA has been omitted from section 4.1 of the HIA;
- Furthermore, previously unknown burial grounds such as the graves uncovered as part of the Samy’s Wholesalers (SAHRIS Case ID 6899 https://sahris.sahra.org.za/cases/samys-wholesalers-extension) are known to present across the area. The old Malay Camp is on the border of the development boundary and one can assume that some burials may be present on the outskirts of the old camp boundaries. A thorough investigation of historical maps (which do not appear in the HIA) can highlight these areas and the risks to the project and heritage resources can be assessed;
- The background history of the study area is sparse and does not include sufficient information regarding the history of the city. One literary source (Richardson 2001) is not adequate enough to provide a full understanding of the history of the city. SAHRA requests that this section of the HIA be strengthened though a more detailed description of the heritage of the study area;
- In order for clear recommendations to be provided for implementation with regards to the aerial fibre installation, and the current recommendation that no poles should be erected directly infront of local heritage resources such as open spaces, churches, schools, monuments, cemeteries and other significant buildings or structures, the location of these resources, their significance and the alternative installation methods must be provided. To merely say that it should not occur, will not provide clear guidance and mitigation measures during the construction phase;
- With regards to the early deployment of the fibre network prior to the NHRA process and the alleged damage to champion trees and historical curbstones, Frogfoot must investigate areas where the fibre network deployment had started and report any damage to heritage/champion trees and heritage curb stones to the NCPHRA for their attention;
- The rollout of the deployment of fibre must be provided so that a schedule for archaeological monitoring can be compiled as part of the revised HIA as well as the submission of the close out reports to be submitted upon the completion of each sector;
- As sections of the proposed development are located within areas of high and very high sensitivity for palaeontological resources, a desktop PIA that complies with the 2012 Minimum Standards: Palaeontological Components of Heritage Impact Assessments must be completed as part of the HIA by a qualified palaeontologist. The palaeontologist may submit a Letter of Recommendation for Exemption for further studies should they deem it appropriate.
As stated above, while SAHRA is not opposed to the proposed development nor objects to the provided recommendation measures, however in order to provide clear mitigation measures for the development, more information as noted above, is required. The following must be noted:
- The proposed trenching to be conducted within the areas of Belgravia, Memorial Park and Klisser is appropriate given the heritage significance of these areas;
- The revised HIA would benefit from a discussion with the McGregor Museum regarding heritage resources including archaeological resources and features within the development area. The museum will have databases of sites that may not be in the NCPHRA site database, as well as additional information that will inform the significance assessment of identified heritage resources.
Further comments will be provide upon the receipt of a revised HIA that addresses the concerns noted above.
OfficialDocs:
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Case 16396 - Interim Comment.pdf | 111.7 KB |