Proposed District Plan Submissions Form 5 Submission on publicly notified proposal for policy statement or plan, change or variation Clause 6 of Schedule 1, Resource Management Act 1991 To New Plymouth District Council - Sarah Edwards Date received 21/11/2019 11:45:54 AM Submission #203 Address for service: Urban Aspect Ltd - Kasey Bellamy - Bland & Jackson Surveyors Ltd / 205 PO Box 637 New Plymouth 4340 Phone: (06) 758 6171 Email: [email protected] Wishes to be heard? Yes Is willing to present a joint case? Yes Proposed District Plan Submissions • Could you gain an advantage in trade competition in making this submission? - No • Are you directly affected by an effect of the subject matter of the submission that (a) adversely affects the environment; and (b) does not relate to trade competition or the effects of trade competition - No Submission points Point 203.1 Submission 21 November 2019 Submission on: The Proposed New Plymouth District Plan Submission by: Kasey Bellamy – Planner at Bland & Jackson Surveyors Ltd (BJSL) on behalf of Urban Aspect Ltd Postal Address for service: PO Box 637 New Plymouth 4340 Telephone: (06) 758 6171 Email: [email protected] BJSL wish to be heard in support of their submission If others make a similar submission, BJSL will consider presenting a joint case with them at a hearing BJSL cannot gain an advantage in trade competition through this submission Sites of Significance to Maori 2556, Archaeological Site 2556 Overlays 1.1 My submission: Amend this aspect of the District Plan The client owns the former Taranaki Daily News site on the corner of Currie Street and the Courtenay Street one-way. Under the Operative District Plan, part of site is designated ‘proposed service lane’ (L15) and part of the site is affected by the ‘defined retail frontage’ overlay. No other overlays affect the site under the Operative District Plan. Under the Proposed District Plan, the service lane designation and the ‘defined retail frontage’ overlays continue to apply to the site. In addition, the Proposed District Plan identifies Archaeological Site 2556 and Waahi Tapu Site 2556 as being located on the subject site. The site description is ‘redoubt’ and Ngati Te Whiti are identified as having mana whenua in the area. These sites extend around the central city area. Archaeological Site 2556 and Site of Significance to Maori 2556 denote the defensive entrenchments formed around the town of New Plymouth by Colonial and British forces in the 1860’s – as shown on some historical survey plans and maps. A request was made to Council for information on the sites, particularly the information Council used to determine the site was a Site of Significance to Maori and an Archaeological Site given there is no prior reference to the sites on the Operative District Plan maps. Council intimated that an archaeologist was currently in the process of preparing a report on the sites, a copy of which will be provided once completed. The information provided from Council (attached) includes Thomas Mould’s 1860 survey plan, the New Zealand Archaeological Association (NZAA) site record and W.H Skinner’s survey plan. In this context, it is considered appropriate that both Overlays on the subject site be removed until such a time as the Archaeological Report on the sites is available. It is also considered that Council should do more work to verify the extent of the site and confirm whether it remains before an Overlay is placed on a property. The intent of the rules around Archaeological Sites and Sites of Significance to Maori is to protect sites from inappropriate subdivision, use and development. It is not intended to unnecessarily constrain the subdivision, use or development of land. Based on the information provided by Council, the entrenchments are shown as crossing the subject site only on Thomas Mould’s survey plan. The archaeologist engaged by Council intimated that he used Thomas Mould’s survey plan as it is the most detailed, and closest to the time of the entrenchment, so is most likely the most accurate. He continues to elaborate that the NZAA site record form used W. H Skinner’s survey plan which was submitted to Thomas Humphries who was Surveyor General from 1906-1909, making the Skinner plan a later, interpreted plan, and therefore less likely to be accurate. As a result, he intimated the Proposed District Plan extent differs from the NZAA extent, but this will be rectified in due course. He concludes by stating that the discrepancy will be discussed with the original archaeologist. The NZAA site record specifies the NZAA site number (P19/397), the site type (military – non-Maori), the site name (New Plymouth Entrenchment) and the recorded date (14/06/2012). The recorded features include bastion, fence/fence line and military camp. The site description is provided by way of a quote from the book The New Zealand Wars: A History of the Maori Campaigns and the Pioneering Period: Volume I: 1845-1864: Page 160 written by James Cowan, F.R.G.S and published by R.E Owen in Wellington 1955. The site description is as follows: Shortly after the war began the effective garrison of New Plymouth and its outposts numbered about twelve hundred men, of whom the 65th Regiment made up about half. Marsland Hill, the ancient Maori pa Pukaka, was an excellent headquarters site and place of refuge in case of emergency. It overlooked the town and the country for many miles, and its position just rear of the central settlement made it a suitable citadel. As the war went on and the out-settlers were driven in, and New Plymouth was reduced practically to a state of siege, it was deemed necessary to construct the occupied area and to entrench the town. The accompanying plan shows the line of ditch and parapet, roughly triangular in figure. The sea-beach formed the base, and Marsland Hill citadel the apex; one side of the triangle was along the line of Liardet Street and the other along Queen Street. There were gates on the Devon Road line where this entrenchment intersected it. There were several outposts, some of which were earthworks redoubts, others timber blockhouses. Figure 1: Map of defences – Skinner Plan (provided by Council) The NZAA site record provided is three pages, but a fourth page is included in the information provided from Council which shows a plan titled ‘Plan of New Plymouth, 1860-1861 Showing the line of entrenchment surrounding the town, with Marsland Hill as the citadel’ (see map below). There is no reference as to who the author of the map is. This map shows the entrenchment and a camp crossing into the subject site. Figure 2: Plan of New Plymouth 1860-1861 (final page of NZAA site record provided by Council) A report titled ‘Fortifications of the New Zealand Wars’ commissioned by the Department of Conservation and prepared by Nigel Prickett (2016) describes (p. 119) and maps (p. 114) the New Plymouth entrenchment and palisade system as follows: As a result of the 27 June 1860 defeat of British troops at Puketakauere and Maori control of districts outside New Plymouth, Pakeha military authorities decided in early June to enclose the town within a fortified line. When General Pratt arrived from Melbourne on 3 August the work was rapidly pushed ahead. Outside the entrenchment and palisade, a line of nine blockhouses made up a second defensive line. A continuous work of trenches with earth breastwork or palisades extended from Mt Eliot along Queen Street and Robe Streets to Marsland Hill, across Huatoki Stream to the Liardet-Courtenay Street corner and down Liardet Street to the beach. There were six gates through the defences. Earthworks also enclosed the Marsland Hill ridge south of the stockade and barracks. It is unlikely that there are any surviving remains Figure 3: New Plymouth, showing blockhouse locations and the inner fortified defensive line, winter 1860. Drawing by K. M. Peters (p. 114 Fortifications of the New Zealand Wars report) Based on the final statement made in the description of the New Plymouth entrenchment and palisade system provided in the ‘Fortifications of the New Zealand Wars’ report; and given that the Courtenay Street hill was significantly cut down and significant earthworks undertaken during the construction of the old Taranaki Daily News building – what evidence does Council have to suggest an archaeological component of the entrenchment system remains on the subject property? The information provided by Council includes two survey plans (Mould & Skinner) and the NZAA site record (P19/397). Only the Mould survey plan shows the entrenchment as located on the subject site. The archaeologist engaged by Council provided reasoning as to why the Mould survey plan is likely the most accurate. However, has a physical investigation or walk over the entrenchment system taken place? What about within the subject property? Has the information used to inform the Proposed District Plan been peer reviewed by another Archaeologist? The client has advised that no physical investigation has taken place on his property that he is aware of and our understanding is that this information has not been peer reviewed. Given the discrepancies in the survey plans and historical maps used to inform both the NZAA site record and the Proposed New Plymouth District Plan, it is considered appropriate that an Archaeological Report, along with a physical investigation of the entrenchment system and a peer review of the information used to inform the Proposed District Plan be undertaken prior to the site being marked as an Archaeological Site or a Site of Significance to Maori on the Proposed District Plan.