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Before Hearing Commissioners
at Christchurch
under:
in the matter of:
the Canterbury Earthquake Recovery Act 2011
a direction under section 16(4) to the Canterbury
Regional Council to prepare a ‘Lyttelton Port Recovery
Plan’
and
in the matter of:
Lyttelton Port Company Limited
Submitter
Statement of evidence of Katharine Jane Watson (Heritage)
Dated: 11 May 2015
REFERENCE:
JM Appleyard (jo.appleyard@chapmantripp.com)
ML Nicol (michelle.nicol@chapmantripp.com)
1
STATEMENT OF EVIDENCE OF KATHARINE JANE WATSON
INTRODUCTION
1
My name is Katharine Jane Watson.
2
I have a Master of Arts in Anthropology from the University of
Otago. I have worked as a consultant archaeologist in Christchurch
for 15 years and am director of Underground Overground
Archaeology Ltd.
3
In preparing my evidence I have reviewed:
3.1
The preliminary draft Lyttelton Port Recovery Plan (LPRP);
3.2
Appendix 9 of Lyttelton Port Company Limited’s (LPC)
Information Package provided to Environment Canterbury on
13 November 2014 (Information Package), being the
archaeological assessment prepared by Matthew Carter (then
an employee of Underground Overground Archaeology Ltd)
dated November 2014;
3.3
Appendix 4 of LPC’s Information Package, being the Cultural
Impact Assessment prepared by Dyanna Jolly dated 10
November 2014;
3.4
The archaeological management plan prepared by Matthew
Carter for the Lyttelton Port Reconstruction; and
3.5
The archaeological authority issued by Heritage New Zealand
for the Lyttelton Port Reconstruction (HNZPT 2015/600).
SCOPE OF EVIDENCE
4
I have been asked by LPC to present evidence on the archaeological
assessment undertaken in respect of the works proposed by the
LPRP, and to do by summarising the findings of the Report. This
evidence accordingly relies on and incorporates the more detailed
information that the Report contains.
5
My evidence discusses:
5.1
The impacts of the project upon the archaeological remains at
Lyttelton Port (Port); and
5.2
The measures that will be employed to mitigate the loss of
archaeological sits at the Port.
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6
Although this is not an Environment Court hearing (or a hearing
being conducted under the Resource Management Act 1991), I note
that in preparing my evidence I have reviewed the code of conduct
for expert witnesses contained in part 7 of the Environment Court
Practice Note 2014. I have complied with it in preparing my
evidence. I confirm that the issues addressed in this statement of
evidence are within my area of expertise. I have not omitted to
consider material facts known to me that might alter or detract from
the opinions expressed.
SUMMARY OF EVIDENCE
7
There are 59 recorded archaeological sites on LPC land that are
protected by the Historic Places Act 1993.
8
These archaeological sites have been assessed using Heritage New
Zealand Pouhere Taonga’s criteria and range in archaeological value
from low to high.
9
An archaeological authority has been obtained from Heritage New
Zealand, under section 14 of the Historic Places Act, which allows
for the modification/destruction of 54 of these archaeological sites.
The remaining sites have been excluded from the authority and
permission has not been granted to modify them.
ARCHAEOLOGICAL ASSESSMENT
10
The Port has been the site of human occupation since at least the
16th century, when Ngāti Mamoe settled in the area. Europeans
arrived in the 1840s and set about establishing the Port that still
operates today.
11
Matthew Carter carried out historical research and assessed the
values of the archaeological sites within LPC boundaries, before
assessing the impacts of the project on these values.
12
The archaeological assessment identified up to 10 sites of high
archaeological value (some of these sites may have been destroyed,
but it was not possible to establish this during the assessment, as it
is not known whether or not extant structures were removed before
within the Port was reclaimed).
13
The remaining archaeological sites were identified as being of low to
medium archaeological value, and various recommendations were
made to ensure that the archaeological information about these
sites will be captured before the sites are modified. These methods
include recording archaeological features prior to modification; stand
over monitoring of earthworks by an archaeologist; and site visits
during earthworks.
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14
On this basis, Heritage New Zealand issued an authority to allow 54
archaeological sites to be destroyed, damaged or modified. The
authority is attached and marked “A”.
15
Five archaeological sites were excluded from the archaeological
authority due to their high archaeological value, the fact that the
reconstruction will not affect the archaeological site and/or because
more information is required about the archaeological site. The sites
excluded from the authority are: Battery Point Historic Area (which
is listed by Heritage New Zealand), Henry Le Cren’s house and
wharf, musket trenches, Polhill’s rifle range, and the graving dock (a
Category 1 historic place). A separate archaeological authority will
need to be obtained if any work is to take place that will affect these
archaeological sites.
16
The archaeological authority requires that the archaeological sites
for which it was issued are recorded and analysed using standard
archaeological procedures, and that reports on the archaeological
work are submitted to Heritage New Zealand (and other institutions)
on a regular basis.
17
Of the archaeological sites identified, four are Māori archaeological
sites. Procedures for archaeological work around these sites have
been developed with Ngāti Wheke to ensure that correct tikanga
Māori is followed during work in these areas.
ARCHAEOLOGICAL MANAGEMENT PLAN
18
The archaeological management plan prepared by Matthew Carter
provides guidance to contractors with regard to archaeological sites,
and to help them prepare the archaeology sections of their CEMP.
19
The management plan sets out:
19.1
The role of the contractor, and that of the archaeologist in
relation to archaeological sites;
19.2
Where the high risk areas/sites are;
19.3
Where the low risk areas are (these areas do not require any
further archaeological involvement);
19.4
Which areas are excluded from the archaeological authority;
19.5
The relevant regulatory requirements in relation to
archaeological sites;
19.6
Construction activities that may impact archaeological sites;
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19.7
How to manage the accidental discovery of archaeological
sites;
19.8
How to manage kōiwi; and
19.9
Mitigation measures for managing impacts on archaeological
sites, including details on how and when to engage an
archaeologist, and the advice they can provide.
20
The archaeological management plan has been approved by
Heritage New Zealand and is a legally binding document.
21
The archaeological management plan has been included as a specific
in the CEMP (the evidence of Kim Kelleher explains CEMP in more
detail, and the CEMP forms part of the Information Package).
22
Repairing the paving in Yard 66 at the Port is currently underway
and has successfully implemented the CEMP. Both an archaeologist
and a cultural monitor are on site, monitoring the earthworks as
required.
PUBLIC COMMENTS
23
Some members of the public raised the possibility that the existing
pile moorings in the Port have heritage values. Photographs indicate
that these piles were installed in the 1920s (they were extant by
1926). As such, the piles are not an archaeological site protected by
the Historic Places Act.
24
These pile moorings are part of the fabric of the maritime cultural
landscape that is the Port, but have no other known/specific
heritage values. In addition, this landscape is not a static entity. It
has one that has evolved with time, responding to changing
technologies, economics, politics, etc. The proposal to replace the
moorings with a floating marina is simply another part of that
evolution, and recreational boating will remain part of the Port’s
story.
Dated: 11 May 2015
__________________________
Katharine Jane Watson
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ATTACHMENT A