Case Decision - 197763

The Maritime and Underwater Cultural Heritage (MUCH) unit of the South African Heritage Resources Agency (SAHRA) received the permit application to search for and identify the wreck of the Miles Barton (1861) on 4 March 2022. Review of the application revealed that it lacks proper scientific motivation for a pre-disturbance survey and does not ask any clear archaeological questions. The MUCH unit has therefore, on 25 March 2022, taken the decision to refuse the application. The reasons for this decision are outlined below.

The project’s lack of cooperation with recognised experts in both Chinese and South African maritime archaeology is concerning. The MUCH unit feels that the project team lacks the required expertise to effectively demonstrate its commitment to best practices in maritime archaeology.
There are flaws in the project design. It is limited, lacks a clear methodology, and is focused on salvage of valuable artefacts rather than demonstrating the holistic approach that characterises true archaeological projects. The applicant speculates about the location of the site, its cargo, and the value thereof without providing clear evidence of historical research. The jump from this speculation to the proposed end-goals of the project is vast and demonstrates limited understanding of important steps in bona fide archaeological enquiry.
Although this application is for a pre-disturbance permit, the ultimate goal of the project – i.e. the recovery of priceless artefacts – is not supported by the MUCH unit in this instance and the applicant would be unlikely to receive subsequent excavation and export permits, making the survey a fruitless exercise if it’s goals are centered around the return of artefacts (as yet undiscovered) to China.
The MUCH unit is concerned about some of the team members’ past association with shipwreck sites. We have researched the backgrounds of some of the team members and in doing so encountered evidence of involvement with projects that led to irreversible damage to important archaeological sites.
The issuing of a permit for the proposed work was unanimously opposed by the MUCH unit’s appointed panel of experts consulted as part of the review process.

As the national heritage resources authority established in terms of the National Heritage Resources Act (NHRA), No. 25 of 1999, the State’s implementing agent for the 2001 United Nations Educational, Scientific, and Cultural Organisation (UNESCO) Convention on the Protection of Underwater Cultural Heritage, and the author and implementer of South Africa’s regulations and policies on permitting work on shipwrecks, SAHRA is firmly opposed to the salvage of archaeological artefacts for reasons that fail to display clear archaeological understanding and scientific rigor.
A person who wishes to appeal this decision may do so within fourteen (14) days of the issuing of this letter.