Submissions

Submission on whether St Mary's Alice Springs should be permanently declared a Heritage Place - March 2026

The St Mary’s lot is wholly within the boundary of a sacred site, the key features of which are mature native tree species. Custodians requested that the Authority convey the broader historical significance of St Mary’s, particularly its importance to the many members of the stolen generation who were housed there, and that efforts should be made to commemorate this.

Comment on the Non-Pastoral Use Permit (NPUP) application for Spirit Hills, VRD Pastoral District

Given the likelihood of impact to sacred sites, the Authority recommends if the Pastoral Land Board is minded issuing a NPU Permit, that it includes the requirement for Southern Cross Agriculture to obtain a new Authority Certificate.

Comment on the EIS referral submitted by the Southern Cross Agri Pty Ltd to develop Stage 1 of the Sweetwater Agricultural Development project - September 2025

The proposed works encroach on Aboriginal sacred sites. The proponent was issued with a draft Authority Certificate (over land nearby) showing Aboriginal sacred sites within the proposed Stage 1. The proponent has not applied for an Authority Certificate for most of the area shown in Stages 1-3.

Submission to the Legislative Scrutiny Committee Inquiry into the NT Aboriginal Sacred Sites Legislation Amendment Bill 2025 - April 2025

We are senior law people from across the Northern Territory and we are very concerned that these amendments will erode protections for our sacred sites. We urge the Assembly to not pass this Bill and instead engage in a real consultation process with Aboriginal people across the Northern Territory to bring proper reform to the protection of sacred sites.

Submission to public consultation on the Draft Territory Coordinator Bill - January 2025

The Northern Territory Aboriginal Sacred Sites Act 1989 (the Sacred Sites Act) is not classed as a Scheduled Act under the draft Bill. The draft Bill also states that the powers of the Territory Coordinator may not interfere with or modify the protection of sacred sites.

Comment on the draft standard conditions and risk criteria for exploration and mining activities - July 2024

Mining activities deemed low risk to the environment may still entail significant risk to sacred sites. Currently the processes for Standard Condition Licenses do not address this risk, nor do they provide a clear pathway to the Sacred Sites Act to mitigate this risk.

Submission on whether the Sea Rights Yingapungapu should be permanently declared as a Heritage Place - June 2024

The Sea Rights Yingapungapu is a permanent sand sculpture memorial created in 2018 for the tenth anniversary of the Blue Mud Bay decision, which recognised that Traditional Aboriginal Owners had exclusive rights to lands and waters within the intertidal zone in the Northern Territory. The Authority is supportive of declaring the Sea Rights Yingapungapu as a declared heritage place.

Comment on the Draft Mataranka Water Allocation Plan 2024-34 - June 2024

All the Roper River tributaries in the Mataranka area have a high density of sacred sites. We are pleased that the new water allocation plan recognises the outstanding cultural value of the Roper River and tributaries in the Mataranka area, as well as its unique environmental values.

Comment on proposed changes to the Casuarina Coastal Reserve - April 2024

The proposed park is within the area traditionally occupied by Larrakia people and retains significant cultural importance and a number of Aboriginal sacred sites. It is vital that consultation occurs with Larrakia in relation to the management of the park, to ensure that the cultural values and stories are recognised and protected appropriately.

Feedback on the discussion paper for a future national water agreement - April 2024

Waterways and water places are fundamentally important in Aboriginal culture and spirituality. This is illustrated by the fact that around 5,000 of the sacred site records held by the Authority are water related. Protection of these sacred sites and the values associated with them is paramount to protecting living Aboriginal culture in the Northern Territory.

Comment on the Kuyunba Conservation Reserve Draft Joint Management Plan - April 2024

AAPA comment on the Kuyunba Conservation Reserve Draft Joint Management Plan. The Reserve is located approximately 15 kilometres south-west of Alice Springs in Central Australia and is largely a registered sacred site ‘Kwiyernpe’.

Comment on the Mac Clark Conservation Reserve - Draft Joint Management Plan - April 2024

AAPA comment on the Draft Joint Management Plan for the Mac Clark Conservation Reserve. There are many Aboriginal sacred sites located within the Reserve. Under the Sacred Sites Act, it is unlawful to enter or work on sacred sites except in accordance with an Authority Certificate issued by the Aboriginal Areas Protection Authority.