s term correctional c (stcc), ellington orrectional c … · aboriginal due diligence...

View across the Study Area.

ABORIGINAL DUE DILIGENCE ARCHAEOLOGICAL

ASSESSMENT

SHORT TERM CORRECTIONAL CENTRE (STCC),

WELLINGTON CORRECTIONAL CENTRE, NSW

WESTERN PLAINS REGIONAL COUNCIL

JULY 2016

Report Prepared by

OzArk Environmental & Heritage Management Pty Ltd

for GHD

on behalf of

Department of Justice

This page has intentionally been left blank.

OzArk Environmental & Heritage Management

Aboriginal Due Diligence Archaeological Assessment: Wellington Correctional Centre Temporary Accommodation, Wellington NSW. i

DOCUMENT CONTROLS

Proponent Department of Justice

Client GHD

Project No / Purchase Order No

Document Description Aboriginal Due Diligence Archaeological Assessment: Wellington Correctional Centre Temporary Accommodation, Wellington NSW.

Name Signed Date

Clients Reviewing Officer

Clients Representative Managing this Document OzArk Person(s) Managing this Document

Location OzArk Job No.

Document Status V3.0 FINAL Date 7 July 2016

Draft V1.1 Author to Editor OzArk 1st Internal (Series V1._ = OzArk internal edits)

V1.0: SR to BC 30/6/16

V1.1 BC edit 7/7/16

Draft V2.0 Report Draft for release to client

(Series V2._ = OzArk and Client edits)

V2.0 OzArk to Client 11/7/16


FINAL V3._once latest version of draft approved by client


Prepared For Prepared By

Daniel Mees

Senior Planner

GHD

72 McNamara St

Orange NSW 2800

E: [email protected]

Stephanie Rusden

Archaeologist

OzArk Environmental & Heritage Management Pty. Limited

145 Wingewarra Street (PO Box 2069)

Dubbo NSW 2830

P: 02 6882 0118

F: 02 6882 6030

[email protected]

COPYRIGHT

© OzArk Environmental & Heritage Management Pty Ltd 2016 and © GHD 2016

All intellectual property and copyright reserved.

Apart from any fair dealing for the purpose of private study, research, criticism or review, as

permitted under the Copyright Act, 1968, no part of this report may be reproduced, transmitted,

stored in a retrieval system or adapted in any form or by any means (electronic, mechanical,

photocopying, recording or otherwise) without written permission.

Enquiries should be addressed to OzArk Environmental & Heritage Management Pty Ltd.


Aboriginal Due Diligence Archaeological Assessment: Wellington Correctional Centre Temporary Accommodation, Wellington NSW. ii

Acknowledgement

OzArk acknowledge Traditional Owners of the area on which this assessment took place and pay respect

to their beliefs, cultural heritage and continuing connection with the land. We also acknowledge and pay

respect to the post-contact experiences of Aboriginal people with attachment to the area and to the elders,

past and present, as the next generation of role models and vessels for memories, traditions, culture and

hopes of local Aboriginal people.


Aboriginal Due Diligence Archaeological Assessment: Wellington Correctional Centre Temporary Accommodation, Wellington NSW. iii

EXECUTIVE SUMMARY

OzArk Environmental & Heritage Management (OzArk) has been engaged by GHD (the Client),

on behalf of the Department of Justice (the Proponent) to complete an Aboriginal Due Diligence

archaeological assessment of 16ha of land on Mudgee – Goolma Road (the Study Area) in

Wellington, NSW which has the potential to be impacted by the proposed short term correctional

centre (STCC; the Proposal) at the Wellington Correctional Centre within the Western Plains

Regional Council Local Government Area.

The Proponent is proposing to expand the Wellington Correctional Centre with additional

accommodation, ancillary buildings, access roads and associated services within a portion of

Lot 1 DP 1141897. The Study Area is located 340m south east of the existing Wellington

Correctional Centre.

The fieldwork component of this assessment was undertaken by OzArk on 27 June 2016.

No Aboriginal sites were recorded and no archaeologically sensitive landforms were identified

during the field inspection. The visual inspection also assessed that there is a very low possibility

of the activity adversely impacting Aboriginal cultural heritage values.

Recommendations concerning the Study Area are as follows:

1. The proposed work may proceed without further archaeological investigation under the

following conditions:

a. All land-disturbing activities must be confined to within the assessed Study Area.

Should the parameters of the proposal extend beyond the assessed area, then

further archaeological assessment may be required.

b. Work crews involved in the proposed work should be made aware of the legislative

protection requirements for all Aboriginal sites and objects.

2. In the unlikely event that objects are encountered that are suspected to be of Aboriginal

origin (including skeletal material), the Unanticipated Finds Protocol (Appendix 2) should

be followed.

3. Work crews should undergo cultural heritage induction to ensure they recognise

Aboriginal artefacts (see Appendix 3) and are aware of the legislative protection of

Aboriginal objects under the NPW Act and the contents of the Unanticipated Finds

Protocol.


Aboriginal Due Diligence Archaeological Assessment: Wellington Correctional Centre Temporary Accommodation, Wellington NSW. iv

CONTENTS

Executive Summary ................................................................................................................... iii

1 Introduction ......................................................................................................................... 1

1.1 Brief Description of The Proposal ................................................................................. 1

1.2 Proposed Work ............................................................................................................ 2

1.3 Study Area ................................................................................................................... 2

1.4 Relevant Legislation ..................................................................................................... 3

1.4.1 State Legislation ................................................................................................... 3

1.4.2 Commonwealth Legislation ................................................................................... 5

1.5 Assessment Approach ................................................................................................. 5

2 The Archaeological Assessment ......................................................................................... 6

2.1 Purpose and Objectives ............................................................................................... 6

2.1.1 Aboriginal Archaeological Assessment Objectives ................................................ 6

2.2 Date of Archaeological Assessment ............................................................................. 6

2.3 OzArk Involvement ....................................................................................................... 6

2.3.1 Field Assessment ................................................................................................. 6

2.3.2 Reporting .............................................................................................................. 6

3 Landscape Context ............................................................................................................. 7

3.1 Topography, Geology and Soils ................................................................................... 7

3.2 Hydrology .................................................................................................................... 8

3.3 Vegetation ................................................................................................................... 8

3.4 Climate ........................................................................................................................ 8

3.5 Land–Use History and Existing Levels of Disturbance ................................................. 9

3.6 Conclusion ................................................................................................................... 9

4 Aboriginal Archaeology Background ................................................................................. 10

4.1 Ethno-Historic Sources of Regional Aboriginal Culture .............................................. 10

4.2 Regional Archaeological Context ............................................................................... 11

4.3 Local Archaeological Context ..................................................................................... 13

4.3.1 Desktop Database Searches Conducted ............................................................ 13

4.4 Predictive Model for Site Location .............................................................................. 15


Aboriginal Due Diligence Archaeological Assessment: Wellington Correctional Centre Temporary Accommodation, Wellington NSW. v

5 Application of the Due Diligence Code of Practice ............................................................ 19

5.1 Introduction ................................................................................................................ 19

5.2 Defences under the NPW Regulations 2009 .............................................................. 19

5.3 Application of the Due Diligence Code of Practice to the Proposed Development ...... 19

6 Results of the Site Inspection ............................................................................................ 22

6.1 Sampling Strategy and Field Methods........................................................................ 22

6.2 Project Constraints ..................................................................................................... 22

6.3 Aboriginal Sites Recorded .......................................................................................... 23

6.4 Discussion ................................................................................................................. 23

6.5 Likely Impacts to Aboriginal Heritage from The Proposal ........................................... 23

7 Recommendations ............................................................................................................ 24

References .............................................................................................................................. 25

Plates ....................................................................................................................................... 27

Appendix 1: AHIMS Extensive Search Result .......................................................................... 30

Appendix 2: Aboriginal Heritage: Unanticipated Finds Protocol ................................................ 31

Appendix 3: Aboriginal Heritage: Artefact Identification ............................................................ 32


Aboriginal Due Diligence Archaeological Assessment: Wellington Correctional Centre Temporary Accommodation, Wellington NSW. vi

FIGURES

Figure 1-1: Aerial showing the Study Area in relation to Wellington. ........................................... 1

Figure 1-2: Proposed work showing impact footprint (source: Phillips Smith Conwell 2016)....... 2

Figure 1-3: Aerial showing the Study Area in relation to the Wellington Correctional Centre. ..... 3

Figure 3-1: Environmental context of the Study Area. ................................................................ 8

Figure 4-1: AHIMS search results. ........................................................................................... 15

Figure 6-1. The Study Area showing pedestrian transects and vehicle reconnaissance. .......... 22

TABLES

Table 4-1: Aboriginal heritage: desktop-database search results. ............................................ 13

Table 4-2: Frequency of AHIMS registered site types within the search area. .......................... 14

PLATES

Plate 1: View from a mid-slope landform towards a drainage feature. View to the southeast. .. 27

Plate 2: View along a very ephemeral drainage feature. View to the south. ............................. 27

Plate 3: View along a lower slope landform. View to the west. ................................................. 28

Plate 4: View from the eastern portion of the Study Area towards Wuuluman Creek. View to the

east. ......................................................................................................................................... 28

Plate 5: Exposures afforded by ant hills within the Study Area. ................................................ 29

Plate 6: Thick grass and weed cover throughout the Study Area. ............................................ 29


Aboriginal Due Diligence Archaeological Assessment: Wellington Correctional Centre Temporary Accommodation, Wellington NSW. 1

1 INTRODUCTION

1.1 BRIEF DESCRIPTION OF THE PROPOSAL

OzArk Environmental & Heritage Management (OzArk) has been engaged by GHD (the Client),

on behalf of the Department of Justice (the Proponent) to complete an Aboriginal Due Diligence

archaeological assessment of 16ha of land on Mudgee – Goolma Road (the Study Area) in

Wellington, NSW which has the potential to be impacted by the proposed short term correctional

centre (STCC; the Proposal) at the Wellington Correctional Centre within the Western Plains

Regional Council Local Government Area (LGA; Figure 1–1).

Figure 1-1: Aerial showing the Study Area in relation to Wellington.



1.2 PROPOSED WORK

The Proponent is proposing to construct and operate a 400 bed temporary correctional

accommodation facility with associated infrastructure and services (Figure 1-2). The Proposal is

part of the Prison Bed Capacity Program (PBCP).

Figure 1-2: Proposed work showing impact footprint (source: Phillips Smith Conwell 2016).

1.3 STUDY AREA

The Study Area encompasses approximately 16ha of land within Lot 1 DP 1141897. The Study

Area is located 340m south east of the existing Wellington Correctional Centre on the Mudgee –

Goolma Road near Wellington, NSW (Figure 1-3).



Figure 1-3: Aerial showing the Study Area in relation to the Wellington Correctional Centre.

1.4 RELEVANT LEGISLATION

Cultural heritage is managed by a number of state and national acts. Baseline principles for the

conservation of heritage places and relics can be found in the Burra Charter (Australia ICOMOS

2013). The Burra Charter has become the standard of best practice in the conservation of

heritage places in Australia, and heritage organisations and local government authorities have

incorporated the inherent principles and logic into guidelines and other conservation planning

documents. The Burra Charter generally advocates a cautious approach to changing places of

heritage significance. This conservative notion embodies the basic premise behind legislation

designed to protect our heritage, which operates primarily at a state level.

A number of Acts of parliament provide for the protection of heritage at various levels of

government.

1.4.1 State Legislation

Environmental Planning and Assessment Act 1979 (EP&A Act)

The current project will be assessed under Part 5 of the EP&A Act:

· Part 5: Environmental impact assessment on any heritage items which may be

impacted by activities undertaken by a state government authority or a local government

acting as a self-determining authority



National Parks and Wildlife Act 1974 (NPW Act)

Amended during 2010, the NPW Act provides for the protection of Aboriginal objects (sites,

objects and cultural material) and Aboriginal places. Under the Act (Part 6), an Aboriginal object

is defined as: any deposit, object or material evidence (not being a handicraft for sale) relating to

indigenous and non-European habitation of the area that comprises NSW, being habitation both

prior to and concurrent with the occupation of that area by persons of European extraction, and

includes Aboriginal remains.

An Aboriginal place is defined under the NPW Act as an area which has been declared by the

Minister administering the Act as a place of special significance for Aboriginal culture. It may or

may not contain physical Aboriginal objects.

As of 1 October 2010, it is an offence under Section 86 of the NPW Act to ‘harm or desecrate an

object the person knows is an Aboriginal object’. It is also a strict liability offence to ‘harm an

Aboriginal object’ or to ‘harm or desecrate an Aboriginal place’, whether knowingly or

unknowingly. Section 87 of the Act provides a series of defences against the offences listed in

Section 86, such as:

· The harm was authorised by and conducted in accordance with the requirements of an

Aboriginal Heritage Impact Permit (AHIP) under Section 90 of the Act;

· The defendant exercised ‘due diligence’ to determine whether the action would harm an

Aboriginal object; or

· The harm to the Aboriginal object occurred during the undertaking of a ‘low impact activity’

(as defined in the regulations).

Under Section 89A of the Act, it is a requirement to notify the Office of Environment and Heritage

(OEH) Director-General of the location of an Aboriginal object. Identified Aboriginal items and

sites are registered on Aboriginal Heritage Information Management System (AHIMS).

Any Aboriginal sites within the Study Area are afforded legislative protection under the NPW Act.



1.4.2 Commonwealth Legislation

Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act)

Matters of National Environmental Significance listed under the EPBC Act include the National

Heritage List and the Commonwealth Heritage List, both administered by the Commonwealth

Department of the Environment. Ministerial approval is required under the EPBC Act for proposals

involving significant impacts to National/Commonwealth heritage places.

It is noted there are no Commonwealth or National heritage listed places within the Study Area,

and as such, the heritage provisions of the EPBC Act do not apply.

1.5 ASSESSMENT APPROACH

The current assessment follows the Due Diligence Code of Practice for the Protection of

Aboriginal Objects in New South Wales (Due Diligence; DECCW 2010a).



2 THE ARCHAEOLOGICAL ASSESSMENT

2.1 PURPOSE AND OBJECTIVES

The purpose of the current study is to identify and assess heritage constraints relevant to the

proposed works.

2.1.1 Aboriginal Archaeological Assessment Objectives

The current assessment will apply the Due Diligence process in the completion of an Aboriginal

archaeological assessment, in order to meet the following objectives:

Objective One: Undertake background research on the Study Area to formulate a

predicative model for site location within the Study Area;

Objective Two: Identify and record objects or sites of Aboriginal heritage significance within

the Study Area, as well as any landforms likely to contain further

archaeological deposits; and

Objective Three: Assess the likely impacts of the proposed work to Aboriginal cultural

heritage and provide management recommendations.

2.2 DATE OF ARCHAEOLOGICAL ASSESSMENT

The fieldwork component of this assessment was undertaken by OzArk on 27 June 2016.

2.3 OZARK INVOLVEMENT

2.3.1 Field Assessment

The fieldwork component of the heritage assessment was undertaken by:

· Archaeologist: Stephanie Rusden (OzArk Project Archaeologist; BSc University of

Wollongong, BA (Archaeology) University of New England).

2.3.2 Reporting

The reporting component of the heritage assessment was undertaken by:

· Report Author: Stephanie Rusden;

· Reviewer: Ben Churcher (OzArk Principal Archaeologist, BA(Hons) University of

Queensland; Dip Ed University of Sydney).



3 LANDSCAPE CONTEXT

An understanding of the environmental contexts of a Study Area is requisite in any Aboriginal

archaeological investigation (DECCW 2010b). It is a particularly important consideration in the

development and implementation of survey strategies for the detection of archaeological sites. In

addition, natural geomorphic processes of erosion and/or deposition, as well as humanly

activated landscape processes, influence the degree to which these material culture remains are

retained in the landscape as archaeological sites; and the degree to which they are preserved,

revealed and/or conserved in present environmental settings.

3.1 TOPOGRAPHY, GEOLOGY AND SOILS

The Study Area falls within the NSW South Western Slopes Bioregion (SWSB) and is comprised

wholly of the Mullion Slopes landscape unit (Figure 3–1). The topography of the Mullion Slopes

landscape unit is characterised by steep hills and strike ridges (Mitchell 2002: 64). Geology

features andesite, conglomerate, tuff, rhyolite, shale, quartzite, quartz and limestone while soils

comprise stony uniform sand and loam in extensive rock outcrop along crests, stony red and

brown soil on slopes and yellow contrast soil in valleys (Mitchell 2002: 64).

The Study Area comprises a gently undulating landform which slopes to the west towards a very

ephemeral drainage feature. The western-most portion consists of a lower-slope landform which

rises to the west where a steep hill adjoins the Study Area. The visible geology of the Study Area

includes large cobbles of sedimentary materials and red-brown loam soil with gravel inclusions.



Figure 3-1: Environmental context of the Study Area.

3.2 HYDROLOGY

Hydrological features within the Study Area are limited to a very ephemeral drainage feature

which runs on a north–south alignment through the western portion of the Study Area. Outside

of, but within the immediate vicinity of the Study Area, a dam has been constructed to capture

water within this drainage feature. The ephemeral waterway, Wuuluman Creek, a tributary to the

Macquarie River is located, at its closest, 150m from the Study Area (Figure 3–1).

3.3 VEGETATION

Prior to European occupation, Mitchell (2002: 64) models that the vegetation within this landscape

unit would have comprised grey box woodlands with red stringbark, red ironbark and tumbledown

gum.

The Study Area’s vegetation has been largely cleared during agricultural use of the area. Thick

grass and weed cover dominates the Study Area with only isolated stands of mature vegetation

present.

3.4 CLIMATE

Climate statistics are taken from Wellington that is located approximately 4.4km south of the

Study Area. The Wellington area has a mild climate with a maximum average temperature



occurring in January (32.9°C) and minimum average temperature occurring in July (2.2°C). The

average rainfall per year in Wellington is 616.1mm (BoM 2016).

3.5 LAND–USE HISTORY AND EXISTING LEVELS OF DISTURBANCE

Disturbance, historical or natural, potentially alters the archaeologically record. It can do this in a

variety of ways, directly or indirectly. For example, land clearing directly removes a particular site

type - usually scarred trees or stone arrangements. Indirectly, land clearing accelerates soil

erosion, potentially resulting in previously buried occupation / activity sites becoming exposed

and altered / damaged.

The Study Area has undergone variable levels of ground surface disturbance over the past

150 years. The majority of the land has been cleared, with few remnant mature trees remaining,

and it is likely that the Study Area was ploughed historically resulting in altered soil profiles and

disturbed sub-surface deposits had they been present. Additional disturbances throughout the

Study Area include the installation of optical fibre cable, a gas pipeline, sewer valves and the

construction of a water tank.

3.6 CONCLUSION

Overall, the landscape context provided above suggests that Aboriginal occupation in the vicinity

of the Study Area is likely to have occurred; especially given the presence of a nearby ephemeral

tributary to the Macquarie River that could potentially have provided Aboriginal people in the past

with resources to sustain sporadic occupation. No permanent waterways intersect the Study Area

that would have sustained repeated long-term occupation. The high level of ground surface

disturbance across the entirety of the Study Area from activities such as vegetation clearance,

cultivation and grazing would have affected the intactness of any subsurface deposits associated

with archaeological sites, if they had been present. As such, unobtrusive sites such as open

artefact scatters, where present, are likely to be disturbed and broad-scale vegetation clearance

characteristic of the area reduces the likelihood that culturally modified trees remain situ.



4 ABORIGINAL ARCHAEOLOGY BACKGROUND

4.1 ETHNO-HISTORIC SOURCES OF REGIONAL ABORIGINAL CULTURE

According to Tindale’s map of tribal boundaries (1974), the Dubbo area falls within the northern

limits of Wiradjuri country, as defined by the limits of the Wiradjuri language group. The Wiradjuri

are typically described as a large language group or tribal nation who extend over a considerable

area of New South Wales and consist of many individual groups. According to Horton (1994), the

boundary of the Wiradjuri extends somewhat further to the north and west to encompass

Gilgandra, Nyngan and most of the Bogan River.

Oral history was passed down through the local Aboriginal inhabitants from parent to child.

Members of the Gallanggabang Traditional Owners (GTO; now part of the Wellington Valley

Wiradjuri Aboriginal Corporation) state that the Wellington tribes were more closely associated

with tribes from the Mudgee area than that of Dubbo.

The earliest written account of Aboriginal people in the Wellington region is from the early

explorers Oxley, Evans and Cunningham. Little information was recorded within the explorers’

diaries during this time period in relation to the Aboriginal presence.

The Wellington valley was settled in 1823, very early in the European occupation of the district.

This area in particular has had a complex sequence of local Aboriginal camps and settlements

as it was the first place where organised missions were established in Wiradjuri territory (Kabaila

1998: 11). Growing Wiradjuri resistance in 1822/23 was followed by the implementation of martial

law in 1824 where it is reported that several hundred people were killed and at this time the

Aboriginal resistance fighter, Windradyne (aka Saturday), become infamous. Shortly after this

period the appointed commandant of the convict settlement established friendly relationships with

the Wiradjuri. However, the following recorded history varies between amenable and violent

associations, from the perspective of the military style commanders of the time (Kabaila 1998:

13–17).

In 1839 a plan for the township of Wellington was drawn up, but objections from Reverend Watson

concerning the impact it would have on the Aboriginal mission caused the village to be

established at Neurea. This village never developed (Whitehead 2003: 328) and the township

was soon relocated to the current site of Wellington.

According to the GTO many Wellington families can trace their ancestry back to people living

within the fringe camps or missions from this time period. Although information specifically about

the daily life of the Aboriginal people of the area is scant, the location of several ceremonial

grounds are still known which are located on obvious features in the landscape (Mt Nanima and

toward the Mt Arthur ranges). The majority of material remains relating to past Aboriginal culture

no longer exist as most of them were created from organic materials that have not survived the



ravages of time or the onset of European settlement. Some objects were collected by early

settlers and have since passed into museum collections, while descriptions of others can be found

in early historic accounts.

4.2 REGIONAL ARCHAEOLOGICAL CONTEXT

Prior to 1985, no systematic, regional based archaeological studies had been undertaken in the

Dubbo area. There were, nonetheless, many sites recorded, generally by interested locals or

amateurs. In the late nineteenth and early twentieth century, individuals such as Gresser and to

a lesser extent Garnsey, recorded site data and made collections of artefacts thereby contributing

to the body of archaeological data now available to the researcher.

The most relevant research-based studies were undertaken by Pearson (1981)1 and Koettig

(1985). Together these provide baseline data for placing past Aboriginal sites within a regional

landscape context. Following is a summary of the salient points learned from these studies:

Pearson (1981) worked primarily in the Upper Macquarie region, the western boundary of his

study area being Wellington. The study area makes the findings of this work relevant. The majority

of Pearson’s field coverage was directed by information from informants and was thus skewed

toward large or obtrusive sites, which had been recognised by local residents. Pearson excavated

three rock shelter sites (Botobolar 5, and Granites 1 and 2) which provided a regional record of

Aboriginal occupation dating back to around 5,000 years before present. Pearson’s analysis of

the patterns of Aboriginal occupation involved an examination of site location characteristics in

four sample areas.

According to Pearson archaeological sites could be divided into two main categories, occupation

sites and non-occupation sites (which included grinding grooves, scarred or carved trees,

ceremonial and burial sites etc.). An analysis of the location of these sites led him to build a model

for site prediction along the following lines (Pearson 1981:101).

· Site distance to water varied from 10 to 500m, but in general larger sites are found closer

to water.

· Good soil drainage and views over watercourses are important site location criteria.

· Most sites were located in contexts, which would originally have supported open

woodlands.

· Burial sites and grinding grooves were situated as close to habitation areas as geological

constraints would allow.

· Ceremonial sites such as earth rings (‘bora grounds’) were located away from campsites.

1 M. Pearson’s 1981 study is an unpublished PhD thesis from the ANU. The authors have been unable to directly access this work

and rely heavily on summaries presented in Koettig (1985).



· Stone arrangements were also located away from campsites in isolated places and

tended to be associated with small hills or knolls or were on flat land.

· Quarry sites were located where stone outcrops with desirable working qualities were

recognised and were reasonably accessible.

· Based on ethnohistoric information, Pearson suggests that Aboriginal campsites were

seldom used for longer than three nights and that large archaeological sites probably

represent accumulations of material over a series of short visits.

The location of non-occupation sites was dependent on various factors relating to site function.

For example, grinding grooves only occur where there is appropriate outcropping sandstone, but

as close to the occupation site as possible. Modified trees were variably located with no obvious

patterning, other than proximity to watercourses, where camps were more frequently located.

Although a useful study, Koettig (1985:49–50) considered Pearson’s findings as preliminary,

mainly due to the unsystematic nature of the recording of most sites used in the analysis. In her

view, this would have skewed both site type (obvious manifestations) and location (areas of

disturbance), therefore biasing the sample. Further the sample size of both the Wellington and

other areas were considered too small to yield significant results.

Koettig (1985) undertook a comprehensive study of evidence relating to Aboriginal occupation

within the Dubbo area, including 5km around the city limits. As a result of the desktop component

of this study, Koettig determined there was need for systematic survey to ensure that all

topographic landform units and different stream order associations were explored in terms of site

type and location. This field work included detailed recording of various site types, ensuring the

presence of comparative, quantifiable data. The field survey was undertaken by dividing the

broader Dubbo study area into five sample survey areas covering the three major physiographic

zones, but was constrained by time and an inability to access privately owned land.

As a result of this study, Koettig (1985:81–82) arrived at the following conclusions.

· Aboriginal sites may be expected throughout all the landscape units surveyed.

· The most frequently occurring site types were open artefact scatters, scar trees and

grinding grooves.

· The location of sites and their relative size were determined by various factors,

predominantly environmental and social. Although social factors cannot be explained

through archaeological research, some of the environmental issues may be. These are:

· Proximity to water: the largest campsites were located close to permanent water,

nonetheless, sites were found all over the landscape including hills and ridges

away from obvious water.

· Geological formation: Certain sites require specific conditions, e.g. grinding

grooves occur where appropriate sandstone outcrops, quarries are found where



suitable stone resources are accessible, burials tend to be found in sandy

sediments such as alluvial flats etc.

· Availability of food resources: The widest range of potential foods was found along

the main water courses due to the supply of permanent water. Some foods would

have been seasonal and required foraging away from water courses.

In predicting intensity of occupation, Koettig suggests that larger and more constantly occupied

sites are likely to occur along permanent watercourses, while less intense and sporadic

occupation evidence is seen along ridge tops or temporary water sources e.g. creek headwaters.

The North-Central Rivers study undertaken by Balme (1986) contributed to our knowledge of the

archaeology of the region by looking at site location with reference to preservation, both in the

face of natural and incursive processes. Findings concluded that apart from the effect of historic

impacts on sites, the greatest influence on the distribution of sites is that of geomorphic processes

affecting site preservation and subsequent processes leading to site exposure (Balme 1986:182).

Balme also found there was little scope for the assessment of the chronology of prehistoric sites

as so few datable contexts have been located. Finally, and relevant to the current study, was

Balme’s finding that a number of sites recorded on the AHIMS register from ethnographic

accounts are no longer likely to be found.

In 2006, OzArk was commissioned to undertake a cultural heritage review of the Dubbo LGA

(OzArk 2006). This project overlaid all recorded sites within the LGA on mapped

geomorphological GIS layer landforms. Results of this study (Stage 1 and Stage 2) confirmed

that most Aboriginal sites are recorded within 100m of water.

4.3 LOCAL ARCHAEOLOGICAL CONTEXT

4.3.1 Desktop Database Searches Conducted

A desktop search was conducted on the following databases to identify any potential previously-

recorded heritage within the Study Area. The results of this search are summarised in

Table 4–1 and presented in detail in Appendix 1.

Table 4-1: Aboriginal heritage: desktop-database search results.

Name of Database Searched Date of Search Type of Search Comment

Commonwealth Heritage Listings 24.6.16 Western Plain Regional LGA

No places listed on either the National or Commonwealth heritage lists are located within the Study Area

National Native Title Claims Search 24.6.16 NSW No Native Title Claims cover the Study Area.

OEH AHIMS 23.6.16 6 x 6km centred on the Study Area

Four sites returned within the designated search area.



Name of Database Searched Date of Search Type of Search Comment

Local Environment Plan (LEP) 24.6.16 Wellington LEP of 2012

None of the Aboriginal places noted occur near the Study Area.

A search of the OEH administered AHIMS database returned four records for Aboriginal heritage

sites within the designated search area (Table 4–2 and Figure 4–1).

Table 4-2: Frequency of AHIMS registered site types within the search area.

Site Type Number Frequency %

Potential Archaeological Deposit (PAD) 2 50

Artefact scatter 1 25

Isolated find 1 25

Total 4 100

The four previously recorded sites are located within 2.5km of the Study Area, with the closest

located 650m to the northeast. AHIMS site #36-4-0099 is an isolated find located along the

eastern bank of Wuuluman Creek recorded by Lloyd Nolan in 2003.

AHIMS site #36-4-0108 is located 1.8km southeast of the Study Area along a ridge line and is a

low density artefact scatter comprising 10 artefacts. The site was first identified in 2004 by ERM

as part of the Investigation of Cadonia Estate Route Options: Wollar to Wellington Proposed

330kV Transmission Line for TransGrid, however, the site was never recorded on AHIMS

following the assessment. In 2005, OzArk completed an archaeological assessment for the

Wollar-Wellington Electricity Transmission Line Assessment. The location AHIMS site #36-4-

0108 was inspected by OzArk during the survey at the location of proposed structure 271. The

site was not identified during the survey with ground surface visibility (GSV) recorded as being at

around 10%. Therefore as no artefacts were identified, the site was not recorded. The site location

was revisited in 2009 by OzArk along with members of the Gallanggabang Aboriginal Corporation

during drier conditions which increased GSV. A number of artefacts were recorded at the site

during this inspection, including flakes made primarily of grey chert and quartz. The site was then

registered on AHIMS by OzArk in 2009.

In 2010, two potential archaeological deposits (PADs), AHIMS site #36-4-0117 and #36-4-0118

were recorded by Colin Pardoe as part of the Young to Wellington Gas Pipeline: Cultural Heritage

Assessment and Consultation. The PADs are both located along the bank on a tributary to the

Macquarie River, approximately 2.3km south of the Study Area.



Figure 4-1: AHIMS search results.

4.4 PREDICTIVE MODEL FOR SITE LOCATION

Across Australia, numerous archaeological studies in widely varying environmental zones and

contexts have demonstrated a high correlation between the permanence of a water source and

the permanence and/or complexity of Aboriginal occupation. Site location is also affected by the

availability of and/or accessibility to a range of other natural resources including: plant and animal

foods; stone and ochre resources and rock shelters; as well as by their general proximity to other

sites/places of cultural/mythological significance. Consequently sites tend to be found along

permanent and ephemeral water sources, along access or trade routes or in areas that have

good flora/fauna resources and appropriate shelter.

In formulating a predictive model for Aboriginal archaeological site location within any landscape

it is also necessary to consider post-depositional influences on Aboriginal material culture. In all

but the best preservation conditions very little of the organic material culture remains of ancestral

Aboriginal communities survives to the present. Generally it is the more durable materials such

as stone artefacts, stone hearths, shell, and some bones that remain preserved in the current

landscape. Even these however may not be found in their original depositional context since

these may be subject to either (a) the effects of wind and water erosion/transport - both over short

and long time scales or (b) the historical impacts associated with the introduction of European

farming practices including: grazing and cropping; land degradation associated with exotic pests



such as goats and rabbits and the installation of farm related infrastructure including water-

storage, utilities, roads, fences, stockyards and residential quarters. Scarred trees may survive

for up to several hundred years but rarely beyond.

Knowledge of the environmental contexts of the Study Area and a desktop review of the known

local and regional archaeological record, the following predictions are made concerning the

probability of those site types being recorded within the Study Area:

· Site location:

o Sites could potentially be recorded on all landforms within the Study Area

although there is a high likelihood, given the distance to permanent water, that

the Study Area landforms do not hold great archaeological potential.

· Site type:

o Isolated finds may be indicative of: random loss or deliberate discard of a single

artefact, the remnant of a now dispersed and disturbed artefact scatter, or an

otherwise obscured or sub-surface artefact scatter. They may occur anywhere

within the landscape but are more likely to occur in topographies where open

artefact scatters typically occur.

§ As isolated finds can occur anywhere, particularly within disturbed

contexts, it is predicted that this site type could be recorded within

the Study Area.

o Open artefact scatters are defined as two or more artefacts, not located within a

rock shelter, and located no more than 50m away from any other constituent

artefact. This site type may occur almost anywhere that Aboriginal people have

travelled and may be associated with hunting and gathering activities, short or

long term camps, and the manufacture and maintenance of stone tools. Artefact

scatters typically consist of surface scatters or sub-surface distributions of flaked

stone discarded during the manufacture of tools, but may also include other

artefactual rock types such as hearth and anvil stones. Less commonly, artefact

scatters may include archaeological stratigraphic features such as hearths and

artefact concentrations which relate to activity areas. Artefact density can vary

considerably between and across individual sites. Small ground exposures

revealing low density scatters may be indicative of background scatter rather than

a spatially or temporally distinct artefact assemblage. These sites are classed as

'open', that is, occurring on the land surface unprotected by rock overhangs, and

are sometimes referred to as 'open camp sites'.

Artefact scatters are most likely to occur on level or low gradient contexts, along

the crests of ridgelines and spurs, and elevated areas fringing watercourses or

wetlands. Larger sites may be expected in association with permanent water

sources.

Topographies which afford effective through-access across, and relative to, the

surrounding landscape, such as the open basal valley slopes and the valleys of

creeks, will tend to contain more and larger sites, mostly camp sites evidenced

by open artefact scatters.



o As a majority of the Study Area is within a sloping landform distant to

permanent water, this site type is not predicted to be common. However,

in flat landforms, present in the southern portion of the Study Area, this

site type is possible although the moderate degree of disturbance in the

Study Area will probably mean that artefact scatters, had any been

present, have become displaced. It is likely that any sites associated with

such landforms are likely to have a low artefact density and a low

complexity of tool types as the sites are either one-off events or only

infrequently used. Previously recorded sites in the vicinity of the Study

Area show a close relationship between semi-permanent watercourses

and elevated landforms.

o Aboriginal scarred trees contain evidence of the removal of bark (and sometimes

wood) in the past by Aboriginal people, in the form of a scar. Bark was removed

from trees for a wide range of reasons. It was a raw material used in the

manufacture of various tools, vessels and commodities such as string, water

containers, roofing for shelters, shields and canoes. Bark was also removed as

a consequence of gathering food, such as collecting wood boring grubs or

creating footholds to climb a tree for possum hunting or bark removal. Due to the

multiplicity of uses and the continuous process of occlusion (or healing) following

removal, it is difficult to accurately determine the intended purpose for any

particular example of bark removal. Scarred trees may occur anywhere old

growth trees survive. The identification of scars as Aboriginal cultural heritage

items can be problematical because some forms of natural trauma and European

bark extraction create similar scars. Many remaining scarred trees probably date

to the historic period when bark was removed by Aboriginal people for both their

own purposes and for roofing on early European houses. Consequently the

distinction between European and Aboriginal scarred trees may not be clear.

§ This site type has a lower likelihood of occurring based on the

overall high levels of land clearance, although some individual

mature trees have potential to be present and these may bear

scars. It is also noted that this site type is very rare at a regional

level.

o Quarry sites and stone procurement sites typically consist of exposures of stone

material where evidence for human collection, extraction and/or preliminary

processing has survived. Typically these involve the extraction of siliceous or fine

grained igneous and meta-sedimentary rock types for the manufacture of

artefacts. The presence of quarry/extraction sites is dependent on the availability

of suitable rock formations.

§ This site type could be recorded within the Study Area should

suitable rock outcroppings be available.

o Burials are generally found in soft sediments such as aeolian sand, alluvial silts

and rock shelter deposits. In valley floor and plains contexts, burials may occur

in locally elevated topographies rather than poorly drained sedimentary contexts.

Burials are also known to have occurred on rocky hilltops in some limited areas.

Burials are generally only visible where there has been some disturbance of sub-

surface sediments or where some erosional process has exposed them.



§ Although it is possible that this site type could be found within the

Study Area, it is considered a rare site type especially given the

disturbance that has occurred within the Study Area.

· Site preservation:

o In areas impacted by ploughing, vegetation clearance, construction of a water

tank and the installation of fibre optic cable, gas pipeline and sewer valves,

archaeological sites will likely have been destroyed had they existed; although

dispersed archaeological material may survive out of context.



5 APPLICATION OF THE DUE DILIGENCE CODE OF PRACTICE

5.1 INTRODUCTION

The NPW Act advocates a Due Diligence process to determining likely impacts on Aboriginal

objects. Carrying out Due Diligence provides a defence to the offence of harming Aboriginal

objects and is an important step in satisfying Aboriginal heritage obligations in NSW.

5.2 DEFENCES UNDER THE NPW REGULATIONS 2009

The first step before application of the Due Diligence process itself is to determine whether the

proposed activity is a “low impact activity” for which there is a defence in the NPW regulations

2009. The exemptions are listed in Section 7.5 of the Regulations (DECCW 2010a: 6).

The activities of the Department of Justice do not fall into any of these exemption categories.

Therefore the Due Diligence process must be applied.

Relevant to this process is the assessed levels of previous land-use disturbance.

The regulations (DECCW 2010a: 18) define disturbed land as follows:

Land is disturbed if it has been the subject of a human activity that has changed

the land’s surface, being changes that remain clear and observable.

Examples include ploughing, construction of rural infrastructure (such as dams

and fences), construction of roads, trails and tracks (including fire trails and tracks

and walking tracks), clearing vegetation, construction of buildings and the

erection of other structures, construction or installation of utilities and other similar

services (such as above or below ground electrical infrastructure, water or

sewerage pipelines, stormwater drainage and other similar infrastructure) and

construction of earthworks.

5.3 APPLICATION OF THE DUE DILIGENCE CODE OF PRACTICE TO THE PROPOSED

DEVELOPMENT

To follow the generic Due Diligence process, a series of steps in a question answer flowchart

format (DECCW 2010a: 10) are applied to the project impacts and Study Area and the responses

documented.

The following paragraphs address the Due Diligence for the Proposal.

Step 1: Will the activity disturb the ground surface or any culturally modified trees?

Yes the activity will disturb the ground. Go to Step 2.



Step 2: Are there any:

a) Relevant confirmed site records or other associated landscape feature

information on AHIMS? and/or

b) Any other sources of information of which a person is already aware? and/or

c) Landscape features that are likely to indicate presence of Aboriginal objects?

a) No. A search of the AHIMS database returned no previously recorded Aboriginal sites within

the Study Area (see Appendix 1).

b) Although the Study Area has not been previously assessed, the background literature review

set out in Sections 4.2 and 4.3 does not indicate that further information concerning the Study

Area is available. There are no known locations of Aboriginal cultural significance within the

Study Area. While Aboriginal community consultation is not a formal requirement of the Due

Diligence process (DECCW 2010a Section 5) it is noted that the Proponent may wish to

consider undertaking consultation if it will assist in informing decision making.

c) Landscape features noted here include (DECCW 2010):

• within 200m of waters, or

• located within a sand dune system, or

• located on a ridge top, ridge line or headland, or

• located within 200m below or above a cliff face, or

• within 20m of or in a cave, rock shelter, or a cave mouth

and’ is on land that is not disturbed land (see Section 5.2) then you must go to Step 3.

Yes. The Study Area is located at its closest, 160m from a semi-reliable water source, Wuuluman

Creek. A drainage feature runs throughout the western-most portion of the Study Area, however,

this does not constitute a permanent or semi-reliable water source.

An answer of ‘yes’ to Step 2 advances the process to Step 3.

Step 3: Can harm to Aboriginal objects listed on AHIMS or identified by other sources of

information and/or can the carrying out of the activity at the relevant landscape features

be avoided?

No: There are no known Aboriginal sites within the Study Area, however the activity will impact

landforms within 200m of a waterway.

An answer of ‘no’ to Step 3 advances the process to Step 4.

Step 4: Does a desktop assessment and visual inspection confirm that there are Aboriginal

objects or that they are likely?

No: The Study Area has been disturbed as previously described in Section 4.6. The visual

inspection (detailed in Section 6) assessed that there is a very low possibility of the activity



adversely impacting Aboriginal cultural heritage values. Trees of scar-bearing age within the

Study Area were checked for cultural scarring and none were observed.

A ‘no’ answer for Step 4, results in the following outcome (DECCW 2010a):

AHIP application not necessary. Proceed with caution. If any Aboriginal objects are

found, stop work and notify OEH (Office of Environment and Heritage). If human

remains are found, stop work, secure the site and notify NSW Police and OEH.



6 RESULTS OF THE SITE INSPECTION

6.1 SAMPLING STRATEGY AND FIELD METHODS

Standard archaeological field survey and recording methods were employed in this study (Burke

& Smith 2004). Pedestrian based visual inspection was employed to ground-truth existing levels

of disturbance within the Study Area starting from the western portion of the Study Area to the

eastern portion. Areas that had been subject to lower levels of disturbance were inspected during

the visual inspection while all areas of exposure were inspected. In addition to this, all mature

vegetation was inspected for cultural modifications. The inspection was recorded by photograph

and GPS, with relevant notes written along the way.

Figure 6–1 illustrates pedestrian coverage of the Study Area and Plates 1 to 6 provide an

environmental overview of the Study Area.

Figure 6-1. The Study Area showing pedestrian transects and vehicle reconnaissance.

6.2 PROJECT CONSTRAINTS

There were no constraints to the successful completion of the assessment and the surveyor was

able to access the entire Study Area. GSV was very low across the Study Area due to the

presence of thick grass and weed cover. Areas of exposures were afforded by ant hills, areas

underneath trees where vegetation has been removed by kangaroos and motorcycle tracks.



Despite the low GSV in some areas, all landforms within the Study Area could be adequately

assessed.

6.3 ABORIGINAL SITES RECORDED

No Aboriginal sites were recorded during the assessment. In addition, no landform within the

Study Area was assessed to be likely to contain further, subsurface archaeological deposits.

6.4 DISCUSSION

High amounts of vegetation prevented GSV across the majority of the Study Area. Nonetheless

all areas of exposure were checked for archaeological material and as a result no Aboriginal sites

were recorded and no archaeologically sensitive landforms were identified.

The predictive model presented in Section 4.2 indicated that site types such as isolated finds

and artefact scatters were the most likely sites to be present within the Study Area although no

new sites of these types were recorded. Scarred trees were also assessed as being likely to occur

should mature native vegetation be present. All mature trees within the Study Area were

inspected for cultural scarring and no scarred trees were identified.

6.5 LIKELY IMPACTS TO ABORIGINAL HERITAGE FROM THE PROPOSAL

As no Aboriginal sites or archaeologically sensitive landforms were recorded within the Study

Area there will be no impact to Aboriginal cultural heritage arising from the Proposal.



7 RECOMMENDATIONS

Under Section 89A of the NPW Act it is mandatory that all newly-recorded Aboriginal sites be

registered with OEH AHIMS. As a professional in the field of cultural heritage management it is

the responsibility of OzArk to ensure this process is undertaken.

No Aboriginal sites were recorded during this assessment.

The following recommendations are made on the basis of these impacts and with regard to:

· Legal requirements under the terms of the NPW Act whereby it is illegal to damage,

deface or destroy an Aboriginal place or object without the prior written consent of OEH;

· The findings of the current investigations undertaken within the Study Area; and

· The interests of the Aboriginal community.

Recommendations concerning the Study Area are as follows:

1. The proposed work may proceed without further archaeological investigation under the

following conditions:

a. All land-disturbing activities must be confined to within the assessed Study Area.

Should the parameters of the proposed work extend beyond the assessed area,

then further archaeological assessment may be required.

b. Work crews involved in the proposed work should be made aware of the legislative

protection requirements for all Aboriginal sites and objects.

2. In the unlikely event that objects are encountered that are suspected to be of Aboriginal

origin (including skeletal material), the Unanticipated Finds Protocol (Appendix 2) should

be followed.

3. Work crews should undergo cultural heritage induction to ensure they recognise

Aboriginal artefacts (see Appendix 3) and are aware of the legislative protection of

Aboriginal objects under the NPW Act and the contents of the Unanticipated Finds

Protocol.



REFERENCES

Australia ICOMOS 2013 International Council on Monuments and Sites 2013. The Burra Charter: The

Australia ICOMOS Charter for Places of Cultural Significance, 2013.

Balme 1986 Balme, J. North Central Rivers Archaeological Project. Report to: National

Parks and Wildlife Service, NSW.

BoM 2016 Bureau of Meteorology 2016. Climate Statistics for Australian Locations:

Wellington, Accessed 27 June 2016.

Burke & Smith 2004 Burke, H. and Smith, C. 2004. The Archaeologist’s Field Handbook,

Blackwell, Oxford.

DECCW 2010a DECCW. 2010. Due Diligence Code of Practice for the Protection of

Aboriginal Objects in NSW. Department of Environment, Climate Change

and Water, Sydney.

DECCW 2010b DECCW. 2010. Code of Practice for Archaeological Investigation of

Aboriginal Objects in New South Wales. Department of Environment,

Climate Change and Water, Sydney.

Garnsey 1942 Garnsey, E.J. 1942. A Treatise on the Aborigines of Dubbo and District:

Their Camp-Life, Habits and Customs. Dubbo: Dubbo Museum and

Historical Society.

Gresser 1941 Gresser, P. 1941. Old Aboriginal Campsites, Stone Arrangements, Dubbo,

NSW.

Horton 1994 Horton, David (ed.) The Encyclopaedia of Aboriginal Australia. Canberra:

Aboriginal Studies Press.

Kabaila 1998 Kabaila, P (1991) Wiradjuri Places: The Macquarie River Basin and some

places visited. Vol.3.

Koettig 1985 Koettig, M. 1985. Assessment of Aboriginal Sites in the Dubbo City Area,

Report to Dubbo City Council.

Mitchell 2002 Mitchell, P. 2002. NSW Ecosystems Database Mapping Unit Descriptions.

Groundtruth Consulting.

OzArk 2005 OzArk EHM. 2005. Wollar-Wellington 300kV Electricity Transmision Line.

Report to International Environmental Consultants Pty Ltd.

OzArk 2006 OzArk EHM. 2006. Aboriginal Heritage Study: Dubbo Local Government

Area. Report to: Dubbo City Council.



OzArk 2009 OzArk EHM. 2009. Investigation of issue surrounding three Aboriginal sites

along the Wellington end of the Wollar-Wellington Electricity Transmission

Line (ETL).

Pardoe 2010 Pardoe, C. 2010. Young to Wellington Gas Pipeline Cultural Heritage

Assessment and Consultation. Report to ERM Power PTY Ltd.

Pearson 1981 Pearson, M. Seen through Different Eyes: Changing Land Use and

Settlement Patterns in the Upper Macquarie River Region of NSW from

Prehistoric Times to 1860. [PhD thesis] Submitted to the Department of

Prehistory and Anthropology, The Australian National University.

Tindale 1974 Tindale, N.B. Aboriginal Tribes of Australia: Their Terrain, Environmental

Controls, Distribution, Limits, and Proper Names. Berkeley: University of

California Press.

Whitehead 2003 Whitehead, J. 2003. “Tracking and Mapping The Explorers” Volume 1 The

Lachlan River Oxley, Evans, and Cunningham. Southern Cross University

Printery: Lismore.



PLATES

Plate 1: View from a mid-slope landform towards a drainage feature. View to the southeast.

Plate 2: View along a very ephemeral drainage feature. View to the south.



Plate 3: View along a lower slope landform. View to the west.

Plate 4: View from the eastern portion of the Study Area towards Wuuluman Creek. View to the east.



Plate 5: Exposures afforded by ant hills within the Study Area.

Plate 6: Thick grass and weed cover throughout the Study Area.



APPENDIX 1: AHIMS EXTENSIVE SEARCH RESULT



APPENDIX 2: ABORIGINAL HERITAGE: UNANTICIPATED FINDS PROTOCOL

An Aboriginal artefact is anything which is the result of past Aboriginal activity. This includes stone

(artefacts, rock engravings etc.), plant (culturally scarred trees) and animal (if showing signs of

modification; i.e. smoothing, use). Human bone (skeletal) remains may also be uncovered while

onsite.

Cultural heritage significance is assessed by the Aboriginal community and is typically based on

traditional and contemporary lore, spiritual values, and oral history, and may also take into

account scientific and educational value.

Protocol to be followed in the event that previously unrecorded or unanticipated Aboriginal

object(s) are encountered:

1. All ground surface disturbance in the area of the finds should cease immediately the finds

are uncovered.

a) The discoverer of the find(s) will notify machinery operators in the immediate vicinity

of the find(s) so that work can be halted; and

b) The site supervisor will be informed of the find(s).

2. If finds are suspected to be human skeletal remains, then NSW Police must be contacted

as a matter of priority.

3. If there is substantial doubt regarding an Aboriginal origin for the finds, then gain a qualified

opinion from an archaeologist as soon as possible. This can circumvent proceeding further

along the protocol for items which turn out not to be archaeological. If a quick opinion cannot

be gained, or the identification is positive, then proceed to the next step.

4. Immediately notify the following authorities or personnel of the discovery:

a) OEH; and

b) Relevant Aboriginal Community Representatives.

5. Facilitate, in co-operation with the appropriate authorities and relevant Aboriginal

community representatives:

a) The recording and assessment of the finds;

b) Fulfilling any legal constraints arising from the find(s). This will include complying with

OEH directions; and

c) The development and conduct of appropriate management strategies. Strategies will

depend on consultation with stakeholders and the assessment of the significance of the

find(s).

6. Where the find(s) are determined to be Aboriginal Objects, any re-commencement of

construction related ground surface disturbance may only resume in the area of the find(s)

following compliance with any consequential legal requirements and gaining written

approval from OEH (as required).



APPENDIX 3: ABORIGINAL HERITAGE: ARTEFACT IDENTIFICATION

Retouched blades (scale = 1cm) Flakes

Microliths (scale = 1cm) Scrapper (scale = 1cm)

Flake characteristics (scale = 1cm) Core from which flakes have been removed (scale = 1cm)

s term correctional c (stcc), ellington orrectional c … · aboriginal due diligence...

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