Case Decision - 196343

The South African Heritage Resources Agency (SAHRA) would like to thank you for submitting the Draft Environmental Impact Assessment Report for the Proposed Gas to Power Powership Project at the Port of Ngqura and Coega SEZ, Nelson Mandela Bay Metropolitan Municipality, Eastern Cape, South Africa.
The project entails the generation of electricity from floating mobile powerships moored in the Port of Ngqura including three ships berthing during the project lifespan namely a Floating Storage Regasification Unit (FSRU), and two Powerships. A subsea gas pipeline will connect the FSRU to the powership and a transmission line from the powership will feed the substation and national grid.
Although most of the proposed project is land based, the Maritime and Underwater Cultural Heritage (MUCH) unit is required to comment on the proposed subsea gas pipeline. The FSR indicates that there are two proposed alternative routes for the pipeline, the first is routed along the eastern edge of the existing breakwater towards the craft basin and is approximately 1.4km long, the 2nd alternative is routed along the eastern breakwater and existing roads and is approx. 0.7km long. The pipeline will be brought to site in sections and assembled ready for installation, the pipeline is likely to be mounted on small footings.
SAHRA commented on the Draft Scoping Report (DSR) in December 2020 where it was noted that although a Heritage Impact Assessment (HIA) had been undertaken to assess any possible impacts on terrestrial heritage, no work was undertaken to assess any impacts on maritime heritage. Despite this, the MUCH unit at SAHRA considered the possibility of any impact on maritime heritage resources to be low due to the extensive development of the area in previous years and so it was recommended that “…the laydown area for the pipeline must be surveyed for heritage resources prior to the laying of the pipeline. Should the survey data reveal any resources of interest, input on mitigation of impacts to such resources must be sought from a suitably qualified specialist.” SAHRA also advised that “…there is still a chance that historic remains could be uncovered during the works. In this case all works must cease and may not commence until SAHRA has been contacted to advise the way forward.”
In January 2021 SAHRA received a letter from maritime archaeologist Vanessa Maitland containing a brief desktop study of the MUCH resources at the Port of Ngqura. This indicated that both areas proposed for the laying of the pipeline had already been extensively dredged far below the historic ground level and concluded that it is extremely unlikely that any heritage resources remain. She noted in her letter the presence of unknown wooden wreckage lying in the inshore area of the proposed pipeline and recommended that the area is monitored by an archaeologist during excavations for the pipeline.
SAHRA responded to the letter in January 2021 and agreed to the terms set out in the letter and supported the mitigation measures.
SAHRA is therefore disappointed to note that the DEIA makes no reference to maritime heritage despite part of the project being below the high-water mark and despite the inclusion of a MUCH report as an addition to the HIA. SAHRA’s comments which were provided for the DSR phase of the project have not been considered for inclusion in the DEIA and the mitigation measures recommended in the MUCH report have not been added into the document.
While the possibility of encountering maritime heritage is considered to be low, mitigation measures must be referenced in the EIA so that should heritage resources be encountered during the proposed work, then the correct protocol will be followed.
SAHRA insists that a paragraph must be inserted under section 8.3.12 (Heritage, Archaeology and Palaeontology) to note the need for input on mitigation of impacts to maritime and underwater cultural heritage resources should they be discovered during the pipeline laydown area survey. Section 4.2.1 must also refer to Maritime heritage to show that its presence has been considered.