Heritage or Conservation Management Plans (HMPs/CMPs) are vital tools that provide an opportunity to conserve and manage heritage sites for future generations to enjoy. However, most of these HMPs/CMPs are developed specifically for site conservation in the context of tourism or research purposes. However, there is a clear gap for effective HMPs/CMPs within the development context when one looks at the amount of large scale operations such as mines, wind and solar farms etc. These developments have the potential to have a significant impact on vast areas and innumerable heritage resources within their respective development footprints and impact areas. The management of heritage sites within an area outlined for development requires a different approach to HMPs/CMPs. CMPs/HMPs aim to conserve heritage sites, while Development Heritage Management Plans (DHMPs) aim to manage the activities and phases of a development that may impact heritage resources within the application area.

As part of the mandate as directed in the National Heritage Resources Act, No 25 of 1999 (NHRA), the South African Heritage Resources Agency (SAHRA) and other relevant Heritage Resources Authorities (HRAs) are required to provide comments on development cases conducted in terms of the National Environmental Management Act, No 107 of 1998 (NEMA), and the NEMA Environmental Impact Assessment (EIA) 2014 Regulations. As part of these investigations, an assessment of heritage resources within the proposed development footprint is completed in the form of a Heritage Impact Assessment (HIA) in terms of the NHRA.

As a result of the HIA, some heritage resources identified within the proposed development footprint can be safely retained in situ upon the approval of the relevant Heritage Resources Authority (HRA). In order to ensure that the in situ heritage resources are not negatively impacted throughout the life of the development, they require ongoing management and monitoring. An HRA should request that a DHMP be developed to ensure no accidental or indirect impact occurs during all phases of the proposed development.

When one does a quick search on the South African Heritage Resources Information System (SAHRIS), one can see that many CMP/HMPs written for developments follow the guidelines published by SAHRA in 2006. SAHRA Site Management Plan Guidelines list the following steps for the development of these plans:

1. A team must be formed to compile the CMP. This team can include specialists from various fields, managers and legal advisors. Relevant stakeholders must be informed and partnerships should be formed;
2. Information must be gathered about the heritage site, both tangible and intangible information. A condition survey of the site must be conducted to establish the status quo;
3. Cultural significance of the site must be determined and key issues identified. A SWOT analysis[1] must be conducted and additional stakeholders meetings must be organised to discuss gathered data;
4. Objectives, strategies, an action and a management plan must be developed, including a monitoring and evaluation strategy; and
5. The CMP must be implemented and resources to implement the plan must be identified and allocated, including the responsible authorities. The CMP must be announced to the public and all communication must be recorded.

While the above requirements may be sufficient to manage one heritage site or even a collection of sites, the above list does not address the nature of a development and the various activities and phases that are associated with a development and may threaten heritage resources.

As per Section 24N of NEMA and Appendix 4 of the NEMA EIA 2014 Regulations, an Environmental Management Programme (EMPr) must be completed as a result of the mitigation recommendations from the conducted Basic Assessment Report (BAR) or Environmental Impact Assessment (EIA) and associated specialist studies including HIAs. The EMPr must include (but is not limited to) the following:

• A map which superimposes the proposed activities and associated infrastructure on environmental sensitivity areas of the preferred development site, indicating any areas that should be avoided, including buffer zones;
• A description of the impact management objectives, identifying the impacts and risks that need to be avoided, managed or mitigated as identified through the EIA process for all phases of development;
• A description of proposed impact management actions, identifying the manner in which the impact management objectives and outcomes will be achieved, including action to avoid, modify, remedy, control or stop any action, activity or process which causes pollution or environmental degradation;
• The method and frequency of monitoring of the implementation of impact management actions;
• An indication of the persons who will be responsible for the implementation of the impact management actions;
• A mechanism for monitoring compliance with the impact management actions;
• A programme for reporting on compliance taking into account the requirements as prescribed by the Regulations;
• An environmental awareness programme and any specific information that may be required by the competent authority.

The requirements of an EMPr address the nature of the impacts of a development which includes the different phases such as construction, operational phase and decommissioning, with specific activities per phase.  The extent and nature of impacts to heritage resources will vary per phase and activity, and these impacts need specific mitigation and monitoring procedures in order to effectively manage the in situ heritage resources within the development footprint.

Additionally, mitigation measures provided by other specialist studies may result in secondary impacts to heritage resources. A good example of this is alien vegetation management plans. These plans usually include the systematic removal of alien vegetation from a development footprint; however, these plans often do not consider that fact that the alien vegetation may be located within heritage sites. Uprooting alien vegetation within heritage sites may destroy sensitive stratigraphy, features and specimens. Another example of other specialist mitigation measures that may impact heritage includes stormwater management plans that aim to protect sensitive water bodies from potentially hazardous run-off and erosion. If not designed with an understanding that heritage sites are part of the landscape, the stormwater infrastructure such as berms and gabions may direct hazardous run-off into heritage sites, contaminating the soil and cause erosion.

Very few CMPs/HMPs submitted for developments are compiled so that they conform to the NEMA EIA Regulations. This makes them very difficult to implement and even more so with regards to reporting and auditing. While a great number of developments will only need a few management principles and guidelines to be incorporated into an EMPr or provide a short CMP/HMP detailing specific procedures and reporting timeframes that need to be implemented per phase and activity, the context of the development landscape must be addressed. It must be stressed that while these CMPs/HMPs are written as part of a NEMA process, the CMPs/HMPs must still be submitted to the relevant HRA for comment and approval subject to revisions as per HRAs’ discretion as part of the mandate under the NHRA.

Development CMPs/HMPs can be influenced by other international guidelines and standards such UNESCO HMP Guidelines, International Finance Corporation (IFC) Performance Standards 7 and 8, as well as the International Council on Monument and Sites (ICOMOS) Charters that detail the protection and management of various types of heritage. While the specific details of these guidelines and standards will not need to be included in all development CMPs/HMPs, the overarching principles need to be considered and included.

Well developed CMPs/HMPs also allows for long-term heritage monitoring projects to be undertaken. Long-term monitoring of heritage resources with regards to long-term impacts and site taphonomy is an under-researched field (with the exception of rock art sites) and if conducted effectively, can assist with overall heritage site management throughout the country. In addition to the research potential, there are a number of job creation opportunities with these plans. Environmental Control Officers (ECOs) often do not possess the skills required to implement a complex CMP/HMP, which indicates that individuals with experience in heritage site management could be contracted to implement these plans in full or in part. This may lead to a diversification of skills within the heritage sector, especially if heritage graduates are contracted under a more experienced heritage practitioner to implement a development CMP/HMP and skills transfer occurs through this process.

In conclusion, there is a need for new guidelines to be produced that seeks to address the gaps highlighted above. CMPs/HMPs for the management of heritage resources within the context of a development should be a product of the EMPr requirements as per NEMA EIA Regulations while still including principles of heritage site management as provided by SAHRA, UNESCO, IFC, ICOMOS and many others.

[1] A SWOT analysis comprises an analysis of Strengths, Weaknesses, Opportunities and Threats associated with the element in question

Natasha Higgitt graduated from the University of Pretoria with an Honours degree in Archaeology in 2010; thereafter she started out her career as an intern at the Archaeology Department in the Albany Museum, Grahamstown. Once her internship ended she started a new internship and permanent position at Digby Wells Environmental, an environmental consultancy company where she worked for 4.5 years. Here she gained experience in Heritage Impact Assessments (HIAs), Resettlement Action Plans (RAPs), Stakeholder consultation and Legal Audits in South and West Africa. She currently works as a Heritage Officer: Impact Assessments in the Archaeology, Palaeontology and Meteorites (APM) Unit at the South African Heritage Resources Agency (SAHRA).