Case Decision - 198829

The South African Heritage Resources Agency (SAHRA) would like to thank you for submitting the Final Basic Assessment Report (FBAR) for the proposed Searcher Seismic Survey Reconnaissance Basic Assessment project. 
While SAHRA understands that the FBAR has been submitted to the relevant competent authority for decision making and that the commenting period has passed, the following concerns have been noted. 
We note that the Seismic Survey does not directly impact National Estate as described in Section 3 of the NHRA and we have no objections to the proposed project. 
However, SAHRA is disappointed to note that the comments that were issued by SAHRA in response to the Draft BAR (12.9.2022) and in response to the letter (10.10.2022) have not been considered in the Final BAR. 
These comments were in regard to the lack of consideration for tangible heritage both in the DBAR and the accompanying HIA. In the comments SAHRA requested that “the existing HIA be updated to consider maritime heritage and to include mitigation measures should any shipwrecks be recorded.” 
The letter written by the heritage practitioner (dated 4.10.2022) and issued in response to SAHRAs comment stated that:
 “We appreciate the concerns raised. We must, however, note that the depth of the seafloor in the specific application area varies between 1500, and 3600, meters (SLR, 2022). We do not foresee that there can be any impact on wrecks on the seafloor at those depths due to the proposed survey activity. 
The potential of discovering unknown wrecks with the 3D seismic survey is also very slim due to the depth and resolution of data recorded. However, research has shown potential for discovering wrecks at depth, and examples of exploration identifying wrecks at 1600mbsl exist (Irion, 2022; Church et al, 2004). 
Considering the above, we propose that the following be included in the Environmental Management Plan for the project:
• survey positioning data and/or any resulting information that could aid in discovering offshore heritage resources, such as shipwrecks, will be shared with SAHRA. 
We believe the additional study for inclusion in the existing HIA will not add to assessing the project's impacts. By adding the proposed management measures, we consider it will be sufficient to address the potential benefits of the survey to ward maritime heritage.” 
In the response to the letter, SARHA requested that that above comment and above assessment for the low possibilities for impacts on any heritage resources must be included in the HIA and BAR and that the above suggested mitigation measures be included in the updated reports. However, this comment has not been considered and the FBAR and HIA have not been updated to reflect these conditions. 
SARHA insists that any EMPr produced as part of the project must include the stated mitigation measures and assessment for heritage. Any anomalies detected during the project that may be related to heritage must be sent to competent maritime archaeologist for assessment and to SAHRA for review. 
As the FBAR has been finalised without the inclusion of SAHRAs comments, this Final comment must be forwarded directly to the Competent Authority for their consideration as per Section 38(8) of the NHRA. Proof of delivery and receipt thereof must be provided to SAHRA.