Peter Nilssen

HERITAGE WESTERN CAPE (HWC)  

MINIMUM STANDARDS FOR PHASE 1 ARCHAEOLOGICAL IMPACT ASSESSMENT (AIA) REPORTS  

Archaeological Impact Assessments are required either as:  

• part of Environmental Impact Assessments (EIAs) submitted to the provincial Department of Environmental Affairs and Development Planning (in terms of the Environment Conservation Act, Act 73 of 1989, and the National Environment Management Act, as amended, Act 107 of 1998), in which case Heritage Western Cape (HWC) is a commenting authority in terms of s.38(8) of the National Heritage Resources Act (Act No. 25 of 1999) and forwards a Record of Decision to this Department, 

• or for developments specified in s.38(1) of the National Heritage Resources Act where a heritage impact assessment (HIA) is required as a result of a Notification of Intent to Develop (NID) to HWC, in which case HWC is the only decision-making authority. 

AIAs submitted for both types are assessed monthly by the Archaeology, Palaeontology and Meteorites Committee (APM) of HWC. Recommendations and decisions made by this Committee are for assessment of archaeological and palaeontological reports only and do not apply to any other decisions that might be required for the built environment or cultural landscape. 

HWC is working on the development of companion minimum standards for Palaeontological Impact Assessment (PIA) Reports. Until these are complete, the AIA minimum standards will be applied to both archaeological and palaeontological reports. 

Phase 1 AIAs are required to: 

• identify any archaeological sites (i.e. certain places with evidence of human activity more than 100 years old), 

• assess their significance, 

• comment on the impact the proposed development will have on them, and 

• make recommendations for mitigation or conservation. 

Phase 2 AIAs might be required for the mitigation (i.e. excavation or sampling) of significant sites before development takes place. 

Phase 3 AIAs might be required for the conservation of highly significant sites before, during and after development. 

1.1.Assessment and Reporting  

Phase 1 AIAs generally involve a field survey of the proposed development site and the report must therefore include: 

a. what type of AIA this is (i.e. s.38(1), or s.38(8); 

b. details of the location of the property to be developed; 

c. location of the sites that are found; 

d. short description of the characteristics of each site; 

e. short assessment of how important each site is; 

f. assessment of the potential impact of the development on the site/s; 

g. in some cases, a shovel test to establish the extent of a site, or collection of archaeological material to identify its associations, (for which a permit will be required); and 

h. recommendations for mitigation or conservation. 

The report is intended to inform the client about the heritage resources and their significance and make appropriate recommendations. It is essential that it also provides HWC with sufficient information about the sites in order for the Committee to assess with confidence and decide: 

a. whether or not it has objections to a development; 

b. what the conditions are upon which such development might proceed; 

c. which sites require permits for destruction; 

d. which sites require mitigation and what this should comprise; and 

e. what measures should/can be put in place to protect sites that should be conserved. 

When a Phase 1 is part of an EIA required by the Department of Environmental Affairs and Development Planning, wider issues such as public consultation and assessment of the spatial and visual impacts of the development might be undertaken as part of the general study and are usually not required from the archaeologist. If however the Phase 1 AIA forms a major component of an Impact Assessment required in terms of s.38(1) of the National Heritage Resources Act (usually referred to as a Heritage Impact Assessment or HIA), it will be necessary to ensure that the study addresses these requirements as specified in s.38(3) and (4). 

1.2.Letter of Recommendation for Exemption  

When a property is either very disturbed (e.g. has been quarried or mined) or is very small and the archaeologist believes it is highly unlikely that any archaeological remains will be found, a letter to HWC can be supplied by the specialist to indicate that there is no necessity for a full Phase 1 AIA report. This must be accompanied by information about the nature of the development and a map and photographic record of the relevant area. 

1.3.Requirements for Permits to Disturb or Destroy Archaeological Sites  

There are three points during development at which HWC may be approached for permission to disturb an archaeological site during the impact assessment process: 

1. Shovel-Test Permits: in particular circumstances (e.g. coastal settings or early colonial urban areas), these are issued to the archaeologist on request prior to or immediately after a Phase 1 survey in order to determine the depth and nature of archaeological deposits below ground level. 

2. Mitigation Permits as part of Phase 2 AIAs: these are for excavation or collection in order to sample and assess sites, and/or to recover materials for radiocarbon dating at sites that will be impacted by the development. The archaeologist must apply for these permits before the Phase 2 study, and after assessment of the Phase 1 AIA report. 

3. Destruction Permits: these are generally issued to the developer after assessment of Phase 2 AIA reports. HWC is likely to request that sites that will be destroyed to make way for development must be radiocarbon dated and later monitored during their destruction. Monitoring allows for the sampling of buried archaeological remains and for the recovery of the contents of unmarked human graves with as little disturbance as possible. 

2. AIAS AND THE NATIONAL INVENTORY  

Phase 1 and Phase 2 AIAs are very often the last opportunity we will ever have to record the remains or evidence of people who lived in this country before us. These records are immensely important to our understanding of the past and as such they form an important part of our National Estate. 

It is important that the quality of these reports is high, that they characterize and date the sites meaningfully, and reflect best practice in terms of the identification, assessment, interpretation and management of our archaeological heritage. These reports might well be consulted many years after their submission, either for the purpose of further heritage management, research, education or heritage tourism among others. 

Developers or specialists may soon be required to provide a copy of the report submitted to HWC to the SAHRA provincial office so that it can form part of the national inventory. 

3. PHASE 1 AIA REPORTS: MINIMUM STANDARDS  

3.1.Every Archaeological Impact Assessment Report must include:  

A. Title Page with: 

a. Title that identifies this report. It should give the name and geographical location of the site(s) and/ or project, including property or farm name, magisterial district, and province; 

b. Author(s) name(s) and details, company name and contact details; 

c. Developer / consultant’s name (who commissioned the report) and their postal address, telephone and fax numbers; 

d. Date (including day and month); 

B. Executive Summary including: 

a. The purpose of the study; 

b. A brief summary of the findings; 

c. The recommendations; and 

d. Any stakeholders or people responsible for decisions and actions. 

C. Table of Contents, for reports longer than 10 pages.  

D. Background Information on the Project with: 

a. whether the report is part of a scoping report/ EIA or HIA (s. 38(1)); 

b. type of development (e.g. low cost housing project, mining, resort); 

c. whether re-zoning and/or subdivision of land is involved; 

d. terms of Reference; and 

e. any other legislative requirements. 

E. Background to the relevant heritage components of the area with: 

a. a literature review and archival research for all relevant heritage components; 

b. reference to museum databases and collections; and 

c. previous relevant impact assessment reports for the area (not only those previously compiled by the AIA’s author). 

This background is required in part to anticipate or predict the kinds of heritage resources that might occur, and in part to gauge the regional significance of archaeological findings made during the current assessment. 

If there is reason to believe that palaeontological resources will be affected, a background scooping report should be forwarded to a Palaeontologist for comment. The report must include all the required locality data and the footprint size of the proposed development to allow the probability of an impact on palaeontological resources to be assessed and evaluated. 

F. Description of the Property or Affected Environment, its setting and heritage resources, with: 

A. Details of the area surveyed including: 

i. full location data for Province, Magisterial District/Local Authority and property (e.g. farm/erf) name and number, etc.; 

ii. location Map(s)/ orthophotos of the general area. These must include the map name and number (e.g. 3318DC Bellville). Maps must include at least a 1:50 000 and (if available) also a 1:10 000 (i.e. most detailed possible). 

a. Title that identifies this report. It should give the name and geographical location of the site(s) and/ or project, including property or farm name, magisterial district, and province; 

b. Author(s) name(s) and details, company name and contact details; 

c. Developer / consultant’s name (who commissioned the report) and their postal address, telephone and fax numbers; 

d. Date (including day and month); 

B. Executive Summary including: 

a. The purpose of the study; 

b. A brief summary of the findings; 

c. The recommendations; and 

d. Any stakeholders or people responsible for decisions and actions. 

C. Table of Contents, for reports longer than 10 pages.  

D. Background Information on the Project with: 

a. whether the report is part of a scoping report/ EIA or HIA (s. 38(1)); 

b. type of development (e.g. low cost housing project, mining, resort); 

c. whether re-zoning and/or subdivision of land is involved; 

d. terms of Reference; and 

e. any other legislative requirements. 

E. Background to the relevant heritage components of the area with: 

a. a literature review and archival research for all relevant heritage components; 

b. reference to museum databases and collections; and 

c. previous relevant impact assessment reports for the area (not only those previously compiled by the AIA’s author). 

This background is required in part to anticipate or predict the kinds of heritage resources that might occur, and in part to gauge the regional significance of archaeological findings made during the current assessment. 

If there is reason to believe that palaeontological resources will be affected, a background scooping report should be forwarded to a Palaeontologist for comment. The report must include all the required locality data and the footprint size of the proposed development to allow the probability of an impact on palaeontological resources to be assessed and evaluated. 

F. Description of the Property or Affected Environment, its setting and heritage resources, with: 

a. Details of the area surveyed including: 

i. full location data for Province, Magisterial District/Local Authority and property (e.g. farm/erf) name and number, etc.; 

ii. location Map(s)/ orthophotos of the general area. These must include the map name and number (e.g. 3318DC Bellville). Maps must include at least a 1:50 000 and (if available) also a 1:10 000 (i.e. most detailed possible). 

Large-scale satellite photographs can also be submitted in addition, but only if in colour. All maps should be preferably A4 in size. A Location Map (aerial or orthophotograph) must have 

iii. the location map must show the size and extent of both the area searched (or GPS “bread-crumb” trail of search), the area to be developed (footprint) and roads and trails accessible by people. If not all of the property was searched, the practitioner must explain why this was not the case and must comment on the probability of sites occurring, and on the relative impact of the development, on the un-searched parts of the property. the polygon of the property concerned marked on it (not just an arrow pointing to it) and full geographical co-ordinates for all relevant points must be given in the text and/or figure caption; and 

iv. It is expected that all likely foci of potential archaeological sites in the affected landscape will be investigated. 

b. Description of the methodology used including: 

i. how the area was searched (e.g. a three-person team for two days, on foot or not); 

ii. what the restrictions to the study were, for example: 

• • visibility affected by high grass or bush or vegetation cover, mobile dunes, walls or concrete surfaces;
• • physical or other impediments (e.g. vlei, swamps, steep kloofs) to the assessment of the area;

and what the likelihood is of sites being found during development based on an assessment of potential resources and previous work in the area; and 

iii. how the data was acquired, and details of research equipment (e.g., GPS, camera). 

G. Description of Sites identified and mapped with: 

a. Details of the location of all archaeological sites including: 

i. site map or aerial photograph of the specific area with the location of all sites marked on it (at least A4 size, referencing the map with name and number, e.g. 3318DC Bellville); 

ii. GPS readings with the model and datum used (WGS 84 and UTM (metric) are considered the most useful), as well as the accuracy. 

b. An adequate description of each archaeological site including: 

i. type of site (e.g. open scatter, shell midden, cave/shelter, colonial dump); 

ii. site category (e.g. Earlier Stone Age, Later Stone Age); 

iii. context (detail description of depositional history and depositional environment); 

iv. the cultural affinities, approximate age and significant features of the site; 

v. estimation or measurement of the extent (maximum dimensions) and orientation of the site(s) (e.g., caves and shelters); 

vi. a record of the depth and stratification of the site (where shovel test permits have been given, and where natural exposures are available), both in the text and through photographs of the sections; 

vii. records of possible sources of information about past environments, such as stalagtites/stalagmites, flowstone, dassie middens, peat or organic rich deposits and natural bone accumulations; and 

viii. photographs of artefacts with a centimetre scale and a caption. Include a ‘wide angle’ photo of the sites. Avoid high contrast situations, e.g. where shadows of the photographer or of section walls fall on the subject matter. 

c. Threats or sources of risk and their impact on the heritage resources (e.g. direct indirect as a result of earth moving, traffic of vehicles or humans, erosion). 

H. Description of the Artefacts, Faunal, Botanical or Other Finds and Features for each site. 

Record meaningful information such as: 

a. raw material; 

b. type of artefact; 

c. maximum dimensions of a sample of artefacts or other relevant materials; 

d. relative frequency of and significant attributes of stone tools observed on the surface; 

e. basic description of ceramics; 

f. description of other artefacts; 

g. description of archaeological features (e.g. hearths, bedding, walling); 

h. basic description of faunal or botanical taxa and estimated frequencies; 

i. adequate photographic and graphic representations of artefacts found, with scale in cm; and cross-reference photographs with a map and co-ordinates showing where the artefacts in the photographs were found (for example, if isolated handaxes are found in a field); and 

j. location of repositories of artefacts, photographs, rock art tracings and field records from other sites in the general area. 

I. Clear Description of Burial Grounds and Graves [a copy must be submitted to SAHRA, as HWC has not yet been given competency on section 36 of the National Heritage Resources Act (NHRA, No. 25, 1999)] including: 

a. clear written and photographic description of any graves; 

b. exact (if head stone present) or estimated age and affinities of the burials; and 

c. clear discussion for the client of the legal implications (include reference to both the Act and the regulations for s. 36 and particularly the public participation process. The latter might be better done by a social consultant). 

J. Field Rating (recommended grading) of the site: 

While grading is ultimately the responsibility of the heritage resources authorities it would be helpful if the report included field rating (proposal for grading) for the site(s), for example: 

a. National: This site is considered to be of Grade I significance and should be nominated as such. 

b. Provincial: This site is considered to be of Grade II significance and should be nominated as such. 

c. Local: this site is of Grade IIIA significance. Mitigation as part of the development process is not advised. The site should be retained as a heritage site (High significance). 

d. Local: this site is of Grade IIIB significance. It should be mitigated and (part) should be retained as a heritage site (High significance). 

e. Generally Protected A: this site should be mitigated before destruction (generally High/Medium significance). 

f. Generally Protected B: this site should be recorded before destruction (generally Medium significance). 

g. Generally Protected C: this site has been sufficiently recorded. It requires no further recording before destruction (generally Low significance). 

K. Statement of Significance giving the significant archaeological heritage value of each site in terms of the legislation (NHRA, section 3 (3) listed below)or in terms of any other relevant criteria, and give reasons. 

a. its importance in the community, or pattern of South Africa’s history; 

b. its possession of uncommon, rare or endangered aspects of South Africa’s natural or cultural heritage; 

c. its potential to yield information that will contribute to an understanding of South Africa’s natural or cultural heritage; 

d. its importance in demonstrating the principal characteristics of a particular class of South Africa’s natural or cultural places or objects; 

e. its importance in exhibiting particular aesthetic characteristics valued by a community or cultural group; 

f. its importance in demonstrating a high degree of creative or technical achievement at a particular period; 

g. its strong or special association with a particular community or cultural group for social, cultural or spiritual reasons; 

h. its strong or special association with the life or work of a person, group or organisation of importance in the history of South Africa; and 

i. sites of significance relating to the history of slavery in South Africa. 

L. Recommendations including: 

a. An assessment of the potential impact of the development on these sites, relative to sustainable social and economic benefits; 

b. Proposals for mitigation or protection relating to: 

i. possible alternatives in the development that might allow the protection and conservation of the sites; or 

ii. the need for mitigation of adverse impacts; or 

iii. the need to conserve sites because of their high heritage value. 

c. Detailed recommendations with regard to burial grounds and graves. This report must inform the client about the full process and enable SAHRA and HWC to make decisions about permits. It must include: 

i. recommendations for protection of the grave(s) from the impact of the development including possibly mitigation (fencing) and recommendation of need for plans for maintenance (mini-management plan); or 

ii. recommendations for relocation of the grave(s) involving public participation an possibly further archival research, 

iii. or both. 

d. An indication of what must be done at each site: 

i. If the site is provisionally rated as of Local Significance (Grade III site, see above point K) and graded with Low Significance the recommendation may be that the site be mapped, documented, minimally sampled for radiocarbon dating if organic material is present, and then destroyed (with a permit). 

ii. If the site is provisionally rated as of Local Significance (Grade III site) and graded with Medium Significance the recommendation may be for a measure of mitigation and radiocarbon dating, after which part or the whole site could be destroyed. Mitigation usually involves a requirement to collect or excavate a sample of the cultural and other remains that will adequately allow characterization and dating of the site. The archaeologist will require a permit for the mitigation and should recommend that the developer acquire a permit / permission for destruction so that the recommended mitigation may be monitored. The archaeologist should monitor this and report to HWC to ensure that this is done. 

iii. If the site is provisionally rated as of Local Significance (Grade III site) and graded with High Significance the recommendation may be that it be formally graded and conserved (e.g. provision of boardwalks, fencing, signage, guides), or conserved and protected as a heritage site (either being listed on the Heritage Register or being declared as a Provincial or National Heritage Site). If sites are to be protected, a Conservation Management Plan will be required. 

e. Recommendations for monitoring of vegetation clearance or other development, as appropriate. 

f. Recommendations for sampling during Phase 2 mitigation based on the significance of the information it is likely to produce 

M. Conclusions. 

N. Bibliography detailing citations in the text of the report. Remember that all sources and publications referring to known archaeological sites in the vicinity should be adequately acknowledged (even the web). 

O. Appendices if any. 

3.2.Phase 1 Archaeological Reports: General Comments  

a. Take into account: 

i. that ephemeral sites may not be unimportant as they may represent the only trace on the landscape of a particular people or period and must be adequately sampled and described so as to supply important information about human presence in the area; 

ii. that bush clearing and construction work (e.g. temporary access roads and camps) may have a strong negative impact on sites; 

iii. that specialists are expected to assess the whole property where the development is targeted. If the whole property is not assessed, the specialist mustindicate why only part of the property is to be affected by short-term and long-term effects of the development; and 

iv. the relative significance of the sites identified in relation to current knowledge of sites in the general area. 

b. Indicate the location of any significant extra documentation or photographic material not included in the report itself. 

c. Provide information and recommendations to the client including the scope of the heritage legislation that applies; the need to apply for permits in good time before disturbing sites in any way; and the need for approval of HWC before the destruction of sites that have been recorded. 

d. Give HWC enough information to assess with confidence whether the recommendations should be approved or modified and whether to issue permission for destruction of sites. 

e. Indicate whether an assessment of the built environment, cultural landscape and/or palaeontological resources are also being commissioned by the developer, and if not, whether this should be done. 

f. Make it clear to the developer that the final decisions about what kind of mitigation or protection is required rest with HWC and that permission is required for destruction. 

g. If a development involves archaeological and/or palaeontological matters only, then the staff serving the APM Committee will issue a ROD. However, if built environment and landscape matters are also part of the proposed project and mitigation, staff serving the APM Committee will issue an initial official letter of comment. Subsequently, staff serving either of these Committees will issue a consolidated ROD where both APM and BELCOM inputs are included.