7 June 2017 Trent Kelly RE: OEH Comments on the Wilton West Precinct Planning Proposal This response has been prepared to address the OEH Comments on the Wilton West Precinct (WWP) Planning Proposal as they relate to the report by Kayandel Archaeological Services (June 2014) Proposed Rezoning “Wilton Junction” Wilton, Wollondilly Shire LGA, NSW: Aboriginal Cultural Heritage Assessment and Historic Heritage Assessment (Kayandel Report 2014).

Bradcorp should update the Aboriginal Heritage Information Management System (AHIMS) search which was carried out 21 January 2013, as the results are out of date. The assessment should include the results of a thorough AHIMS search in the last 12 months.

An extensive AHIMS search centred upon the location of the Wilton West Precinct was undertaken on the 9 June 2017. After the mapping of these results occurred, there are no additional sites within the WWP from those shown in the Kayandel Report 2014. A copy of the Extensive AHIMS Search is included as Attachment 1.

The archaeological survey is inadequate. OEH requires a comprehensive survey in order to identify areas that warrant conservation and should be excluded from the planning proposal at this stage. The survey should also identify management and mitigation outcomes for the archaeological and cultural resource throughout the life of the proposed development. A very brief survey methodology has been provided, which provided no information on survey tracks or survey coverage.

A large portion of the allotments that form the WWP were the subject of archaeological survey and assessment in 2000. Additional survey was undertaken as part of the assessment for the Kayandel Report 2014 in addition to earlier work. WWP is 874 Ha. in size, of this 591 Ha. have been subject to comprehensive survey in either 2000 or 2013/14. This equates to 67% of the area. The remaining 33% is not presently proposed for any form of direct harm, See Figure 4 of the Kayandel Report 2014 for a map showing these two areas. The attached map shows the same information but has been focused on the area of the WWP. As stated above, earlier archaeological assessment was undertaken in 2000. Of the survey units that where investigated in 2013/2014 SUs 12-31 occur within the WWP. See Figure 20 and Table 10 (KAS 2014) provide details on the survey coverage. Relevant records have been extracted below and an map showing the specific survey units for this precinct is attached.

Survey Unit

Landform Survey Unit Area (Ha.)

Length And Width Of Transects

Visibility %

Exposure %

Effective Coverage Area (Sq M)

Effective Coverage % Of Survey Unit

12 mid slope/upper slope

21.28 97500 5 5 2437500 11.454417

13 mid slope/upper slope

45.24 265000 5 5 6625000 14.644768

14 Lower slope 17.30 120000 5 5 3000000 17.346054

15 Upper slope/ridge/flat

42.78 160000 5 5 4000000 9.3508194

16 mid slope/upper slope/ridge

39.55 180000 5 5 4500000 11.377427

17 mid slope/upper slope/ridge

42.56 150000 5 5 3750000 8.8121255

18 mid slope/upper slope

12.66 65000 5 5 1625000 12.835703

19 mid slope/upper slope

28.70 140000 5 5 3500000 12.194697

20 mid slope/upper slope

35.04 150000 5 5 3750000 10.703277

21 mid slope/upper slope/flat/ridge

59.41 325000 5 5 8125000 13.675458

22 mid slope/upper slope/ridge

26.84 155000 5 5 3875000 14.437407

23 Upper slope/ridge

51.63 275000 5 5 6875000 13.315128

24 Upper slope/ridge

33.90 300000 5 5 7500000 22.121284

25 Upper slope 23.38 120000 5 5 3000000 12.833676

26 Upper slope 2.52 32500 5 5 812500 32.254863

27 Lower slope/flat

29.13 210000 5 5 5250000 18.020183

28 Upper slope 13.56 105000 5 5 2625000 19.358407

29 Flat/mid slope 28.61 315000 5 5 7875000 27.524379

30 Mid slope/Lower

10.06 10000 5 10 500000 4.969191

Slope

31 Lower slope/mid slope

12.01 50000 5 5 1250000 10.410594

The landscape surrounding the WWP presents an opportunity of a considerable conservation outcome to be achieved. As noted in Figure 3, there are considerable tracts of land identified as having existing vegetation, much of these areas are associated with the steep terrain and sandstone escarpments in direct relationship with the Nepean River, Cordeaux River and Allens Creek. The areas subject to survey and assessment within Kayandel 2014 were those specifically identified as likely to be subject to direct impacts associated with the development of the Wilton Junction concept. In the Bingara Gorge development to the east of the WWP, the vegetated areas with escarpment and steep terrain are where Aboriginal sites have been shown to be present. It is reasonable to therefore assume that similar environments within the WSEP will share the same types and frequencies of Aboriginal sites that are present within the Bingara Gorge development; on this basis those areas should be considered for protection of their heritage values.

Consultation should be undertaken with the Aboriginal community regarding the proposal, and information supplied that demonstrates the consultation that has been undertaken.

Consultation has occurred with both the Tharawal Local Aboriginal Land Council (TLALC) and the Cubbitch Barta Native Title Claimants Aboriginal Corporation (CBNTCAC). These are the 2 organisations that have a long history for involvement as Aboriginal stakeholders for the Wilton area and are also the only 2 groups that are Registered Aboriginal Parties for recently approved permits in the Wilton area. Comments on the Kayandel 2014 received from CBNTCAC are attached. No comment was received from TLALC although it should be noted they participated in the field survey and were provided with a copy of the report to comment upon. The comments received from CBNTCAC acknowledge the sensitivity of the creek lines and the preference for these areas to be managed as a conservation zones into the future, this view is consistent with the direction that the Proponent has advocated for. CBNTCAC also identifies that some areas had been surveyed previously, this statement does not apply to those lands within the WWP. As identified further consultation will be required to be undertaken in the future to obtain any relevant approvals under Part 6 of the National Parks and Wildlife Act. This consultation will be undertaken in accordance with the Consultation Requirements for Proponents at the appropriate stage in the approvals process.

Yours sincerely,

Lance Syme Principal B Arts (Arch/Paleo), Grad Dip (Heritage Conservation) Full Member International Council on Monuments and Sites (M.ICOMOS) Expert Member International Committee on Archaeological Heritage Management Registered Cultural Heritage Advisor