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Understanding Cultural Heritage Management Plans

If you've just been told by your local council or planning consultant that you need a Cultural Heritage Management Plan (CHMP) before your project can move forward, you probably have three questions:

Do I really need one?
How much will it cost?
How long will it take?

This page answers these questions clearly and explains the requirements of the Aboriginal Heritage Act 2006 (Vic) and the Aboriginal Heritage Regulations 2018. It uses the correct legal and planning terminology so you can understand your obligations and know where your project stands.

This information is provided for general information purposes only. Victoria's Heritage requirements are site-specific and project-specific.

If you would like to discuss your Cultural Heritage Management Plan requirements, please contact us via our web form or phone on 0429 339 923.

What is a Cultural Heritage Management Plan?

A Cultural Heritage Management Plan (CHMP) is a formal report that assesses how a proposed development or land use activity may affect Aboriginal cultural heritage within a project area. It sets out the steps that must be taken before, during and after the activity to protect cultural heritage and reduce any unavoidable impacts.

CHMPs are prepared by a qualified Heritage Advisor with expertise in Aboriginal cultural heritage management. This may include specialists in archaeology, anthropology or cultural heritage studies who meet the requirements of section 189(1) of the Aboriginal Heritage Act 2006.

Once completed, the CHMP must be submitted to the relevant Registered Aboriginal Party (RAP), which is the Traditional Owner group responsible for the area where the project is located. If no RAP has been appointed, the CHMP is assessed by the Secretary of the Department of Premier and Cabinet through First Peoples – State Relations.

Where a CHMP is required by law, planning permits, work authorities, licences and other statutory approvals cannot be issued until the CHMP has been approved. Engaging a qualified Heritage Advisor early can help avoid delays and keep your project on schedule.

Do I need a CHMP? Understanding Legal Triggers

In the Aboriginal Heritage Act 2006, a CHMP is required when two conditions are met at the same time. These conditions are that it is a high impact activity within an area of cultural heritage sensitivity. This requirement is found in regulation 7 of the Aboriginal Heritage Regulations 2018.

Criteria 1. The proposed activity is a "high impact activity"

High-impact activities are defined in Part 2, Division 5 of the Aboriginal Heritage Regulations 2018 and include activities that involve significant ground disturbance. Common examples include:

Residential or commercial subdivision of land
Construction of buildings or structures requiring excavation
Installation of underground utilities and infrastructure
Road construction and major earthworks
Extraction of mineral, stone, sand or gravel resources
Renewable energy infrastructure including wind and solar farms
Major vegetation clearing on identified landforms

There are important thresholds and exemptions that apply to many of the activities that can trigger a CHMP requirement. Part 2, Division 2 of the Aboriginal Heritage Regulations 2018 lists a range of exempt activities and works. These are generally activities that involve little or no ground disturbance, or activities that are already authorised under another approval process.

Because these exemptions can be complex, it's important to seek advice if you're unsure. Strata Heritage can assess your project and determine whether an exemption applies, potentially removing the need for a CHMP.

Criteria 2. The activity area is within an "area of cultural heritage sensitivity"

Areas of Cultural Heritage Sensitivity are specified in Part 2, Division 3 of the Aboriginal Heritage Regulations 2018 and include:

Land within 200 metres of a waterway, wetland, lake or estuary
Land on or within 50 metres of a registered Aboriginal cultural heritage place on the Victorian Aboriginal Heritage Register (VAHR)
Coastal land and coastal dunes
Land contains cave, lunettes, or wetlands.
Volcanic landscapes, lava flows and stony rises
Land subject to specific heritage sensitivity mapping under Schedule 1 of the Regulations

How to check whether your land is in an area of Cultural Heritage sensitivity

There are several free tools available to help you determine whether your project may require a CHMP.

VicPlan's Mapping Tool includes an "Areas of Cultural Heritage Sensitivity" map layer, which you can view free of charge.

You can also use the map on the Aboriginal Cultural Heritage Register and Information System (ACHRIS) to find this information.

Another useful resource is the Aboriginal Heritage Regulations Planning Tool, available through First Peoples – State Relations. By answering a series of questions about your project and site, the tool can help you determine whether a CHMP is likely to be required.

If you're still unsure, Strata Heritage can carry out a preliminary due diligence assessment (sometimes called a cultural heritage due diligence report). This can help clarify your obligations and identify potential cultural heritage issues before you commit to the time and cost of a full CHMP process.

Other triggers for a CHMP

There are several other circumstances under the Aboriginal Heritage Act 2006 where a CHMP may be required or prepared, in addition to the high impact activity and cultural heritage sensitivity test.

These reasons are:

The Minister directs that a CHMP be prepared -The Victorian Minister responsible for Aboriginal heritage can require a CHMP for a project.
The project requires an Environmental Effects Statement (EES) -Large or complex projects that undergo a formal environmental assessment may also need a CHMP.
The project requires certain environmental approvals -Some projects that need approvals under environmental protection laws may require a CHMP as part of that process.
The Secretary determines that a CHMP is required -The Secretary of the Department of Premier and Cabinet can decide that a CHMP is needed for a particular project.
The project sponsor chooses to prepare a CHMP voluntarily -Even when the law does not require a CHMP, a landowner or developer may choose to prepare one to identify and manage Aboriginal cultural heritage risks.

Voluntary CHMPs

A Cultural Heritage Management Plan (CHMP) can be prepared voluntarily, even when the law does not require one.

Some project proponents choose to prepare a voluntary CHMP to engage with Traditional Owners early, better understand potential cultural heritage issues, and reduce project risk before making major decisions such as purchasing land or finalising project designs.

For more complex projects, a voluntary CHMP can provide valuable certainty. Identifying cultural heritage constraints early can help avoid delays, redesigns and unexpected costs later in the planning and approvals process.

What is a Preliminary Aboriginal Heritage Test (PAHT)

A Preliminary Aboriginal Heritage Test (PAHT) is a voluntary process that can provide certainty about whether a Cultural Heritage Management Plan (CHMP) is required for your project.

Through a PAHT, a project proponent can apply to First Peoples – State Relations for a formal determination that a CHMP is not required. If the application is approved, the legal requirement to prepare a CHMP is removed.

A PAHT can be a useful option where there is uncertainty about whether a project triggers the CHMP requirements under the Aboriginal Heritage Act 2006. It allows proponents to seek an official decision before committing to the time and cost of preparing a full CHMP.

What happens if I don't prepare a required CHMP?

Where a Cultural Heritage Management Plan (CHMP) is required, failing to obtain approval before commencing works is an offence under the Aboriginal Heritage Act 2006 and may attract substantial financial penalties.

In practical terms, no planning permit, work authority, or statutory approval can be granted until a CHMP is approved. If construction proceeds without approval, regulators can issue stop-work orders and take enforcement action, resulting in project shutdowns.

Non-compliance presents a material risk to program, cost, and contract delivery. Early engagement and completion of a CHMP is generally the most efficient way to avoid delays and unplanned compliance costs.

Timelines and Process

A CHMP will be developed in stages. These are detailed below:

Stage 1 - Notice of Intent (NOI)

Before any assessment work can begin, Strata Heritage will submit a Notice of Intent to Prepare a CHMP through the ACHRIS system and pay the required statutory fee on behalf of the client/sponsor.

The Notice of Intent must also be provided to:

the relevant Registered Aboriginal Party (RAP)
landowners and occupiers within the activity area
the relevant local council

The RAP then has 14 days to advise whether they intend to evaluate the CHMP. If the RAP does not respond, or chooses not to evaluate the CHMP, the Secretary to First Peoples – State Relations becomes the approval authority.

Stage 2 — Desktop Assessment

Every CHMP begins with a desktop assessment. This involves reviewing existing information about the area, including:

the Victorian Aboriginal Heritage Register
historical maps and aerial photographs
environmental and geological data
previous archaeological reports
landform and landscape information

The desktop assessment helps determine:

whether Aboriginal cultural heritage is likely to be present, and
whether fieldwork is required.

If a Registered Aboriginal Party (RAP) has been appointed for the area, a meeting is held after the desktop assessment to discuss the proposed field assessment methodology, including whether a standard assessment and/or complex assessment will be required.

Stage 3 — Standard Assessment (if required)

If the desktop assessment indicates there is a reasonable possibility that Aboriginal cultural heritage may be present, a standard assessment is required.

This usually involves a pedestrian ground survey of the activity area to:

identify any visible Aboriginal cultural heritage material, and
assess landforms for archaeological potential.

Not all CHMPs require this stage.

Stage 4 — Complex Assessment (if required)

If the standard assessment identifies Aboriginal cultural heritage, or the desktop assessment suggests that subsurface cultural deposits may be present, a complex assessment may be required.

This stage can involve:

hand-excavated test pits
occasional machine-excavated trenches
further archaeological investigation

The purpose is to determine:

whether subsurface cultural heritage is present
the extent of any deposits
their significance and condition

Complex assessments are typically the most time-intensive stage of the process.

Stage 5 — CHMP Report Preparation and Review)

Once all required assessments are complete, Strata Heritage prepares the CHMP report.

The report outlines:

the assessment findings
any Aboriginal places identified during the process
potential impacts of the proposed activity
recommended management conditions

These management conditions may apply before, during, or after works take place.

In some cases, the RAP and/or First Peoples – State Relations may review a draft CHMP before it is formally submitted

Stage 6 — Submission and Evaluation

The completed CHMP is then formally submitted to the relevant approval authority together with the statutory submission fee.

The approval authority has 30 statutory days to:

approve the CHMP, or
refuse approval.

If additional information is requested during this period, the assessment clock pauses until the required information is provided.

Timelines

Timeframes for a Cultural Heritage Management Plan (CHMP) can vary significantly depending on the project’s complexity, site size and conditions, the involvement of the Registered Aboriginal Party (RAP), and whether fieldwork is required.

Desktop-only CHMPs are usually the fastest option. They typically take around 6–12 weeks from commencement to approval, depending on RAP response times and the previous history of land use in the area.

Standard assessment CHMPs generally take about 3–6 months from commencement to approval for an average sized project.

Complex assessment CHMPs vary widely depending on the site. Where significant cultural heritage is identified, salvage excavation is required, or RAP consultation takes longer than expected, timeframes may be extended.

As part of each quote, Strata Heritage will provide an indicative delivery timeframe to support project planning.

Understanding Costs

How much does a CHMP Cost?

Cost is usually the first question clients — and also the hardest to answer upfront. This is because CHMP costs vary depending on the details of the project. In short, the answer is: it depends.

Typical cost range

In Victoria, Cultural Heritage Management Plans (CHMPs) can range from approximately $10,000 to $500,000 or more. The final cost depends on factors such as the size of the project area, the level of assessment required, any Aboriginal cultural heritage identified, and the requirements of the relevant Registered Aboriginal Party (RAP).

To give a general guide:

Due diligence assessment (to check whether a CHMP is required): typically $3,000–$8,000 depending on site size and complexity
Desktop-only CHMP (no fieldwork required): usually $8,000–$20,000
Standard assessment CHMP (including field survey): approximately $15,000–$60,000 for small to medium projects
Complex assessment CHMP (including archaeological excavation): typically $50,000–$500,000+, and may exceed this for large infrastructure or resource projects

What drives the cost

CHMP costs are mainly made up of three components:

Heritage Advisor fees

These cover desktop research, fieldwork, consultation with Registered Aboriginal Parties (RAPs), report writing, and project management. Under the Aboriginal Heritage Act 2006 (s.58), the project proponent (called the Sponsor) must appoint a qualified Heritage Advisor to prepare the CHMP. Fees are negotiated directly between the Sponsor and the Heritage Advisor.

Registered Aboriginal Party (RAP) fees

RAPs charge fees for their role in the CHMP process. This may include reviewing the Notice of Intent to Prepare a CHMP (NOI), assessing the CHMP, attending meetings, providing cultural guidance, and participating in fieldwork. These fees are set individually by each RAP and vary across Victoria.

Other components

Other costs include regulatory fees, travel and accommodations, specialist equipment hire, specialist analysis (such as radiocarbon dating) or photogrammetry.

The most significant factor in the cost is whether a complex assessment is required. Complex assessments involve archaeological excavation, such as test pits, shovel test pits, and sometimes machine-excavated trenches across parts of the site. Some RAPs also require higher-density testing, which can increase both cost and timeframes.

Getting a quote

When requesting a quote, it helps to provide:

The property address and site size (activity area)
Details of the proposed works
Any known heritage information about the site
Project timelines and approval deadlines

This enables Strata Heritage to provide an accurate quotation.