3.2.1 In relation to the avoidance or mitigation of effects Bowers stated that it was her understanding that “the majority of archaeological sites on the property would be avoided during future quarrying operations” (emphasis mine). In the proposed western extension she recommended archaeological monitoring⁶ followed by site avoidance or mitigation.

3.0 Adequacy of Bowers Assessment

3.3.1 Several of the submissions presented in opposition to the resource consent application by Fulton Hogan included criticism of Bowers assessment⁷. The most inclusive is that by Alexy Simmons, then regional archaeologist for the NZ Historic Places Trust. This author also has some concerns regarding Bowers report.

3.3.2 Simmons considered that the assessment had several failings: (i) it did not include a full assessment of effects, (ii) it did not address the requirements to avoid, remedy or mitigate adverse effects, (iii) the value of the sites to iwi should have been sought and been part of the evaluation, (iv) systematic sampling should have been undertaken, (v) monitoring areas of suspected but unproven archaeological features was an inappropriate measure of mitigation, and (v) it was not appropriate to use the provisions of the Historic Places Act in a resource management matter.

3.3.3 Simmons requested a series of conditions be imposed on the applicant: (i) a detailed foot inspection of all areas that were to be affected, and map, record and photograph archaeological evidence, (ii) undertake subsurface sampling using hand and mechanical excavation in areas of possible archaeological features, (iii)

⁵ Archaeological testpitting involves spade holes generally 30 cm square dug into the ground through the topsoil and subsoil layers.

⁶ Bowers used the term monitoring to mean ‘controlled mechanical stripping of selected portions under the guidance of an archaeologist’. This is slightly different to the usual meaning.

⁷ EBOP & WBOPDC 1999, Appendix C. Submissions included Nga Potiki, Ngaiterangi Iwi, Des Kahotea and Simmons for the NZ Historic Places Trust - C27, 28, 30 & 32.