3.2.1 Bowers stated that her aim was to relocate the recorded sites, assess the probable effects of the application on those sites, and give recommendations in mitigation of adverse effects. However, she did not intend to provide an assessment of significance, which would be required for applications to modify sites under the Historic Places Act, and she did not undertake a cultural values assessment as Fulton Hogan were consulting separately with the relevant iwi groups.

3.2.2 In response to questions raised by Western Bay of Plenty District Council, Bowers responded in a letter that was appended to Fulton Hogan’s application for resource consent¹. The additional comments related to: site significance, methodology, avoidance or mitigation of effects.

3.2.3 In relation to site significance Bowers stated that the sites would have “at least local archaeological significance, given that the archaeological investigation of such sites has the potential to provide evidence relating to the history of New Zealand”. Further, she considered that a detailed assessment and evaluation was not warranted unless, or until, an application for an authority was made to the Historic Places Trust to damage, modify or destroy the sites.

3.2.4 In relation to the methodology of assessment, Bowers stated that she walked along all the ridges, and traversed the flatland in a series of transect. She did not undertake any subsurface testing on the ridges because testpitting⁵: (i) would not detect subtle features, (ii) it was unnecessary along the ridges between obvious features recorded as sites as there was a high likelihood of archaeological evidence, and (iii) most of the areas of possible buried archaeological features would not be damaged by quarrying. She did however testpit on the flatland in order to confirm the presence of predominantly gley and organic soils.

³ Bowers 1999a.

⁴ Bowers 1999b, Appendix 7. Note that in this letter she refers to page 10 and 11 of her report, however the copy I have been given only reaches page 8 - Simmons made a similar comment.