Mapungubwe Cultural Landscape

a) Lack of a proper buffer zone (land tenureship issues);

b) Lack of a management plan;

c) Mining activities;

d) Development pressure.

A joint World Heritage Centre/ICOMOS reactive monitoring mission visited the property from 15 to 20 January 2012 to consider the additional Heritage Impact Assessment (HIA) submitted by the Department of Environmental Affairs on 25 November 2011, the potential impact of the proposed large scale coal mining to the east of the property, progress with the delimitation of a buffer zone to the east of the property as identified at the time of inscription, and the overall state of conservation of the property. The mission was also requested by the World Heritage Committee to consider possible mitigation measures in the event that it concluded that the proposed mining might not threaten irreversibly the property's Outstanding Universal Value (OUV) in order that if relevant, the Director General of UNESCO and the Chairperson of the World Heritage Committee could address such measures before the next session of the Committee. The reactive monitoring mission was initially planned from 20 - to 25 November 2011 but postponed to January 2012 following a request from ICOMOS for more time to review the HIA prior to the mission.

The mission report has been transmitted to the State Party and is available at: https://whc.unesco.org/en/sessions/36COM. On 11 May 2012, the State Party submitted a state of conservation report that includes a response to the mission’s recommendations.

a) Mining activities

In Decision 35 COM 7B.44 the World Heritage Committee noted that the State Party had halted opencast mining operations at the Vele site seven km to the east of the property’s boundary to ensure full compliance with the national legislation while a further HIA was carried out. It welcomed the commitment of the State Party to continue halting the mining operations until the mission had assessed the results of the requested additional Heritage Impact Assessment.

The mission discovered that mining operations had resumed although not yet in full operation. The mission was taken to the Coal of Africa Vele site and to the processing plant which was 95% complete and told that mining operations had been re-started but not fully launched Mining was being carried out within the footprint of the opencast mining area in which the company was operating at the time it was ordered to stop operations. The State Party in its report confirmed that mining operations had re-started in November 2011 after the company had received the necessary environmental authorisations from the national authorities.

The mission noted that the visual impact of even this limited version of the opencast pit that Coal of Africa plans for the whole of their south-east area mining operations was already substantial. It questioned as to why Coal of Africa was planning to mine opencast across the south-east area but underground in the north-west area, while the position of the coal seam is more or less the same depth in both areas. Their choice is based on the desire to avoid harming the big commercial citrus farms along Limpopo River and because they consider the areas to the south and south-west as ‘only dry bush land’ with no economic value. It is thus apparent that Coal of Africa could technically mine underground across the entire site but intend to pursue the more profitable opencast mining. This position contrasts with the company’s otherwise stated ambitions to prioritize cultural heritage protection at Vele.

The State Party reported that Coal of Africa is still in the process of gaining membership of the International Council on Mining and Metals (ICMM), and has committed itself to adhering to the standards and policy statements of the ICMM.

b) Heritage Impact Assessment

This additional HIA carried out for Coal of Africa was submitted by the State Party in November 2011. Although the HIA mentions that the ICOMOS Guidance on Heritage Impact Assessment has been taken into account, the methodology that this Guidance sets out has not been fully followed.

The Statement of Outstanding Universal Value (OUV) adopted by the World Heritage Committee was not mentioned in the HIA – only the justification for the criteria at the time of inscription. There was therefore no attempt to identify the attributes that convey OUV, then to consider how the area of the Vele Colliery relates to those attributes and how coal mining might impact on those attributes. As the cultural heritage at Vele is the result of the same historical processes as in the property, there is a need to assess how the archaeological sites and landscape features relate to them. It is clear that Mapungubwe did not exist in isolation but was a fundamental part of a wider area within which states developed on the basis of agriculture made possible by river floods, the exploitation of the hinterland for gold, ivory and trade. 

As a result, the HIA had focused on specific archaeological sites within the mining area without a clear understanding of how they relate to each other in landscape terms or how they relate to the inscribed cultural landscape area. The HIA concluded that any sites within the opencast mining areas could be destroyed once they had been recorded or fenced off within the area of the processing plant. The mission considered that protecting individual sites or undertaking rescue archaeology on individual sites in advance of opencast mining did not equate to the mining operations having ‘minimal impact’ on the landscape, as set out in the HIA.  Once the open cast mining had finished in a particular area, any archaeological sites, or graves of ancestors would have been destroyed, and the re-filled areas would be ‘coal mining ‘ landscapes and not cultural landscapes associated to the sites of the K2 and Mapungubwe period cultural landscapes in the inscribed property, or landscapes of value to the local communities. There is also reason for concern in terms of the water requirements for open-cast mining in an area that already has water shortagesas it could impact adversely on the sustainability of the property.

The mission considered that the major threat to the setting of the property was the opencast mining process. The impact on the landscape setting would be unacceptable and would jeopardise the cultural continuum between the landscape within the property and that in its setting. Furthermore, given the extent of the coal seam under the buffer zone, there is potential for huge swathes of land around the property to be irreversibly damaged in a similar way. By contrast with the opencast mining areas, the underground mining areas could interfere far less with the landscape and be mitigated if appropriate processes were put in place to reduce vibration, and ensure necessary ventilation and escape routes as well as roof support.

The State Party considers that including the whole area of the original Mapungubwe Kingdom in the protected area is not practical and that the OUV as currently protected will not be negatively impacted by mining. However, the importance of the sites that will be destroyed in relation to the setting of the property within the buffer zone envisaged at the time of inscription in 2003 has not been assessed and should therefore be protected.

c) Possible mitigation measures

The mission considered that no mitigation measures were possible to reduce the impact of opencast mining. It did not accept the view put forward in the HIA that recording archaeological sites prior to their destruction was a valid means to safeguard the landscape. In order to mitigate the overall impact of mining, the mission considered it essential for all mining to be underground, with appropriate safeguards related to structural stability, safety of workers and vibrations. Furthermore the mission considered that in order to put in place appropriate mitigation measures related to the impact of roads, plants and vibration from underground mining, and to facilitate future monitoring, it will be necessary for more detailed surveys to be undertaken on the overall Iron Age landscape features, and of sacred features associated with local communities.

The State Party reports that it has signed a Memorandum of Agreement in September 2011 with the mining company. The South African National Parks (SANParks), as the Management Authority, is party to that agreement. This involves cultural heritage and biodiversity offsets programmes and also water and tourism. The State Party in partnership with Peace Parks Foundation (PPF) has appointed a biodiversity offsets specialist to ensure success of the programme. A Task Team with all relevant stakeholders will be established to define the scope and monitor the programme. Negotiations with the mining company will commence soon.

d) Buffer Zone

The HIA report states that the World Heritage Committee did not acknowledge the State Party’s approval of a buffer zone in 2009. In fact, the buffer zone was never submitted to the Committee to approve and assess the adequateness of the delineation, although this was noted as necessary step in the Retrospective Statement of OUV. The mission recommended that the 2009 buffer zone should be formally increased to incorporate the seven km stretch east of the property so as to include the whole area envisaged at the time of inscription, and noted that this stood in opposition to the HIA’s recommendation to even reduce the current national buffer zone.

Although the State Party reports that this stretch is actually in the process of being incorporated into the conservation area (Mapungubwe National Park) to serve as a buffer zone, and that a minor boundary modification should be submitted to the 37th session of the Committee for this purpose, it is not clear how this proposed buffer zone relates to the area envisaged at the time of inscription or to the current mining area.

The State Party report further notes that there is no consensus among the various institutions and stakeholders regarding the meaning, purpose, nature and consequently extent of the property’s buffer zone. The mission stressed that the Committee had in principle approved the buffer zone envisioned at the time of inscription in 2003, which included the area where coal mining is currently under way, and would therefore not agree on the reduced buffer zone gazetted by the State Party in 2009.

The State Party acknowledges the need to resolve these matters to enable effective protection and management of the property, including the transfer of targeted land to the managing authority and the conclusion of the establishment of the Trans-frontier Conservation Area.

The mission noted that the HIA has revealed a large number of applications for prospecting rights in the current nationally adopted buffer zone of 2009, some of which have been approved with around twenty of these relating to the coal mining seam that runs south-west from the Vele area under the buffer zone. Future coal mining areas have been delineated and farms purchased by coal mining companies. The Mission learned that several companies are carefully monitoring the development of the Vele colliery project and considered that there is a need for clear protection policies within the Buffer Zone which prohibit opencast and underground mining.

The State Party stated in its report that “Whilst the State Party is making tremendous efforts to regularize such [mining] activities, however, with full compliance to local legislation and effective monitoring, the impacts can be minimized.” This statement appears to indicate that the State Party is ready to approve even more mining projects in the buffer zone, as has been reported to the mission by the HIA team.

e) State of conservation of the property

The Mission was made aware of several large installations in the northern part of the property that are related to the de Beers Venetia diamond mine on the south of the property. These installations provide the mine with water from the Limpopo River. The mission considered that these have a substantial adverse visual impact.

The State Party stated that it is concerned by this assertion as the Venetia mining infrastructure predates inscription and no adverse impact has been mentioned before.

At the time of inscription, the State Party had agreed to phase out other on-going economic activities within the property. Plans are needed to dismantle or hide the infrastructures of mining in the core area, whether or not they were already there at the time of inscription.

The mission also noted that whereas the Shroda site and Mapungubwe Hill appear to be in a reasonable state of conservation, the K2 archaeological site is seriously deteriorated putting at risk the major source of archaeological evidence for the time when the centralised state of Mapungubwe emerged.

The State Party reports that it has located resources for immediate intervention aimed at improving the situation and this will include condition surveys and rehabilitation of sites such as K2 and Mapungubwe Hill. This conservation intervention should be completed by the end of 2012.

It also reported that a copy of the management plan will be submitted to the World Heritage Centre by 1 February 2013. They also acknowledge the need to revise the plan in line with the recommendations of the mission.

The World Heritage Centre and the Advisory Bodies note that opencast mining was resumed before the mission took place and assessed the results of the requested additional Heritage Impact Assessment. The World Heritage Centre and the Advisory Bodies also note the clear conclusion of the mission that open cast mining would irreversibly damage the setting of the property in terms of the way it supports the cultural landscape of Mapungubwe. They further note that no mitigation measures are possible to reduce the impact of opencast mining, and do not accept the view put forward in the HIA that recording archaeological sites prior to destruction could safeguard the landscape. Although it is clear that sites related to the Mapungubwe Kingdom are widespread and that the most important ones are within the property, the buffer zone, as agreed at the time of inscription, provides the landscape context and setting for the property.

As assurances were given to the mission that there are no technical reasons why Coal of Africa could not mine underground across the entire Vele Colliery site, instead of only near the Limpopo River as currently proposed to protect the citrus farms, the World Heritage Centre and the Advisory Bodies consider that opencast coal mining cannot be justified. They advise that opencast mining operation should stop after the current existing footprint and that all future mining operations in the area of the buffer zone as envisaged at the time of inscription should be carried out underground with appropriate measures being put in place in relation to vibrations, stability of the mines, escape and ventilation measures and arrangements for supporting infra-structures and road transport and safety measures for workers.

The World Heritage Centre and the Advisory Bodies consider that the mining issues have highlighted the need for a buffer zone to be formally put in place around the property, as envisaged at the time of inscription, and with appropriate planning controls to protect the landscape context and setting particularly in relation to mining, as they note the apparent intention of the State Party to authorise further mining projects.

As the OUV of the property relates in particular to the archaeological evidence associated with the sequential development of three separate capitals of the Mapungubwe State between 900 and 1,300 AD, the World Heritage Centre and the Advisory Bodies consider that the integrity of the property could be at risk unless urgent measures are taken to protect, conserve and consolidate the evidence from one of these, Leopard’s Kopje (K2), which the mission reported to be seriously deteriorated. They welcome the assurance of the State Party that conservation work will be carried out during 2012.