The South African Heritage Resources Agency (SAHRA) would like to thank you for your letter in response to the comment issued by SAHRA for the Draft Environmental Impact Assessment (DEIA) 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.
SAHRA commented on the DEIA in March 2021 and noted that the comments which were provided for the DSR phase of the project had not been included in the DEIA and that the report 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 advised that while the possibility of encountering maritime heritage is considered to be low, mitigation measures must be referenced in the EIA so that should maritime heritage resources be encountered during the proposed work, then the correct protocol will be followed. SAHRA re-iterated in the comment for the DEIA that maritime heritage must be considered as part of the project and that mitigation measures must be included in the Final EIA.
SAHRA received a letter from Triplo4 in April 2021 addressing the comment provided by SAHRA for the DEIA. The letter highlights the areas of concern raised by SAHRA, mainly that maritime heritage must specifically be referenced and mitigated, and has addressed these concerns with the following paragraph. “For completeness and better clarity as you have requested, the above points referring to the maritime heritage will be added to the final EIAR in Section 4.2.1 (Cultural Heritage), as well as Section 8.3.12 (Specialists’ Findings and Recommendations – 8.3.12, Heritage, Archaeology and Palaeontology). The mitigations measures within the EMPr will also be further revised to clearly indicate reference to both terrestrial and maritime heritage.”
SAHRA supports these recommendations and is satisfied with the statement from Triplo4 that these measures will be included in the relevant sections of the EIA and the EMPr.
Please note that in Section 8.3.10 of the EMPr the ‘Impact Management Actions’ refer to heritage but the ‘Implementation’ and ‘Monitoring’ sections appear to be referring to wildlife management.
Once the Final EIA is ready, please upload it onto SAHRIS to enable SAHRA to review it and to issue a final comment for the project.
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