A submission against a planned subdivision in Tuross Head claims the project could be on top of an old Indigenous burial ground according to research done by the Australian Institute of Aboriginal Studies (AIAS).
The controversial plans were on public exhibition up until Friday, July 16, and have been met with fierce opposition from the community.
If approved, the plans would see 71 lots developed near Coila Lake between the eastern and western sides of Monash Avenue.
The plans have pre-approval dating back to 1984, and the current DA is an amendment to the original approval.
In a submission seen by the Bay Post, Simon Cox, a community member behind the Facebook group Protect Coila Lake's fragile ecosystem, said research done by AIAS in the 1960s (while it was known as AIATSIS) alongside Harry Warner and local Indigenous elders found several key historic sites on the land.
"The site clearly includes both a gravesite on the eastern side of the development, and a campsite likely full of important artefacts that must be formally studied before development can take place," Mr Cox said in the submission.
The submission also pointed to a 2006 study done by heritage consultant Alistair Grinbergs on the site in question.
"There are exceptional densities of stone artefacts on this development site which have excellent potential to contribute to our knowledge of Aboriginal life in the local area," the submission reads.
"Alistair Grinbergs excavated 11 test pits by hand and found 132 artefacts - the surface area was 3.5 square metres, giving an average density of 37.7 artefacts per square metre.
"One test pit yielded 81 artefacts, extrapolating to 324 artefacts per square metre.
"There could well be more than 100,000 artefacts on this development site."
Mr Cox called for a new heritage study to be done on the site before any decisions were made on the DA.
"A well preserved site would allow for a host of work such as carbon dating that can shed light on how the Brinja Yuin people lived, and how the land was used over millennia," he said in his submission.
"There is a lot to learn from this area, and it should be treated with the utmost respect.
"Rushing through this development (would be) disrespecting the rights of the local first people - in no way should the council consider this cultural heritage complaints of the site to be anywhere close to complete.
"No information has been provided to show any consideration of sensitive Indigenous cultural areas in the original DA approval obtained in 1984."
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A council spokesperson indicated the council wasn't aware of any potential Indigenous burial sites, but could only take into account the most recent modification.
"A previous application lodged in 2012 was supported by a cultural heritage report and General Terms of Approval were issued by the then NSW Office of Environment and Heritage," they said.
"The applicant may be required to obtain permits under this legislation.
"In this instance, the developer commenced this subdivision back in the 1980s, therefor the current consent remains valid.
"Council cannot reconsider that historical approval, it can only assess the impact of the proposed modification.
"Council will remind the applicant of their obligations under the National Parks and Wildlife Act and the Environment Protection and Biodiversity Conservation Act, however Council does not have jurisdiction in these areas."
Applicants Rygate and West have been contacted for comment, but had not responded as of Wednesday afternoon.