Mod 4 - Subdivision Changes

The Stockland application documents outline that the land will be divided into 181 lots; however until this time the area has been a single relatively undisturbed parcel of land. A VCA would ensure that the area under the agreement is registered on the title of the land, ensuring that, if the land is sold, the agreement and management requirements remain in place. However, conservation under a VCA would be made difficult as a result of the landuse change which would occur as a result of the development. That is, the potential for discovering artefacts in lot areas during residential building activities (to be undertaken at a later date by lot purchasers) would be limited and the removal of condition B50 may be appropriate. However, given the proximity to the Sandon Point Aboriginal Place, it would stand to reason that regardless of surface or other sporadic (test-pit style) archaeological investigations which may have been undertaken by Stockland (and which are proposed in the modification to condition E31), there remains high potential for substantial aboriginal heritage deposits beneath the surface of the proposed development, which may be uncovered during initial construction activities. It would be these initial construction activities, which would be protected under the original condition E31 - where there remains high potential for discovering artefacts and where any conservation requirements would be most appropriate.

When I refer to initial construction activities, I refer to construction activities required in order to prepare the lots for sale: that is, the developer would undertake construction works to supply necessary infrastructure (water/stormwater, power, telecom, roadways, etc) to each lot contained in the development and it would be at this stage of the development where Stockland (or their subcontractor) would be the most likely to uncover any such deposits.

My concern is that if Condition B50 is removed and condition E31 is modified (as requested by Stockland's application documentation), that requirements for archaeological supervision and protection during initial construction activities for the development would not be adequate for the site given its proximity to a verified Aboriginal Place.
If Condition B50 is removed, condition E31 should NOT be modified, to ensure that requirements for archaeological supervision and protection during initial construction activities is retained (and not be undertaken as a preliminary investigations prior to construction as per suggested condition E31 modification).

Where a deposit is identified during initial construction activities for the subdivision, it should be preserved and protected.