Historic Places Aotearoa Feed-back on the Proposed Central Government Fast Track Consenting Bill

 Historic Places Logo Purple
The  Voice of Heritage
For New Zealand
Patron Dame Anna Salmond, DBR, FRSNZ, FBA

11 February 2023


The Engagement Lead, Treaty Settlements
Ministry for the Environment
Wellington

Tēnā koe

Historic Places Aotearoa thanks you for this opportunity to provide feed-back on the proposed Fast
Track Consenting Bill, which is intended to enable the prioritisation of locally, regionally, and
nationally significant infrastructure and development projects.

Cultural heritage is a matter of national importance and fundamental to the well-being of individuals
and communities. It includes places and landscapes with historic, cultural, social, scientific,
archaeological, architectural and technological significance as well as sites of significance to Māori,
for example wāhi tapu and wāhi tupuna. It is concerned with identity and cultural matters that are
deeply important to society and may be controversial. Consequently, it is essential that the expert
panel have the ability to effectively mitigate any impacts on heritage from the development of fast-
track projects. This means providing the panel with explicit requirements:
• To acknowledge that heritage is an identity and cultural issue of great importance and may be
controversial.
• To require transparent, fair, and equitable actions to be followed and adhered to.
• To consider a range of cultural heritage values including archaeological, architectural, historic,
scientific, technological, and cultural
• To protect all unknown heritage places until the heritage impacts of development proposals
are assessed.
• To consider a range of mitigation options.
• Mitigation that results in the best heritage outcome while proceeding with the development is
appropriate:
o Offsets (e.g. financial contributions) while providing financial compensation do not
retain the maximum heritage fabric and overlook the social and cultural factors
involved.
o Heritage should not be subject to simple cost/benefit economic balancing, without
including broader community wellbeing benefits in the analysis because once cultural
heritage has been destroyed it is gone forever.
o Replacing with replicas or restoring on an alternative site because it is more
affordable leads to irrevocable loss of heritage.

It is acknowledged that not everything with cultural heritage value can be saved.

• But all the factors involved, not just the economic factors, must be carefully weighed
because many of the attributes of heritage are not included in economic analysis, e.g. historic, cultural
and social, and consequently communities of interest must be involved.

We would appreciate the opportunity to meet with you to discuss our perspectives.

Nāku noa, nā

Elizabeth Pishief PhD (Heritage)
President