The Australian Institute of Architects has called on the Federal Environment Minister to block approval of the Australian War Memorial’s redevelopment proposal arguing that the demolition of Anzac Hall violates legislated heritage protections.

The proposal is currently undergoing assessment as a ‘controlled action’ under the Environment Protection and Biodiversity Conservation Act 1999(EPBC Act) with the public display of final documentation ending today.

The #handsoffAnzacHall campaign spokesperson and former National President Clare Cousins urged the Minister to listen to the feedback from experts, including the government’s own principal heritage advisor, the Australian Heritage Council.

“All of the heritage advice has been consistent in finding that the demolition of Anzac Hall will – unequivocally – have a significant negative impact on the Australian War Memorial’s heritage value,” Ms Cousins said.

“The strength and value of Australia’s legislated environmental and heritage protections would be undermined if such a violation of the Heritage Management Plan for this iconic site were permitted to proceed.

“The Department of Agriculture, Water and the Environment (DAWE), as custodian of our national environmental and heritage protection laws, has a responsibility to be a fair and independent arbiter in assessing the redevelopment proposal.

“In reviewing the final documentation, the Institute is deeply concerned by the record of interactions between DAWE and the Memorial which appear to presuppose that approval to demolish Anzac Hall will be granted.

“DAWE cannot be both project approval facilitator and independent assessor – this represents an irreconcilable conflict.

“According to the documents, DAWE advised the Memorial to undertake a ‘specific social heritage survey’ in February 2020. This followed widespread criticism of the plans to demolish Anzac Hall.

“The Memorial has relied on the results of this survey to argue that there is ‘Broad support…for all elements of the Project including the replacement of Anzac Hall’. However, the copy of the survey included in the EPBC Act documentation appears to contain no specific questions about the demolition of Anzac Hall.

“The final documentation the Memorial has submitted also contains numerous inconsistencies and questionable assertions.

“The Memorial’s analysis of the 167 submissions received contradicts their claims of near-universal support for the proposal with more than 80% of comments opposed to the proposed replacement of Anzac Hall.

“The narrative running throughout the documents that the social heritage benefits of the redevelopment as it is currently proposed justify or outweigh the physical heritage loss is not supported by the consultation records.”

Prior to providing the type of detailed design feedback contained in these EPBC Act assessment documents, DAWE’s responsibility is to first and foremost assess whether the demolition of Anzac Hall is permissible given the unambiguous heritage protections that apply to the site generally and to this gallery specifically.

This assessment rests on whether there are feasible alternatives that avoid adverse impacts on the Commonwealth Heritage values of a Commonwealth Heritage place.

The documents provided by the Memorial demonstrate that 3 out of the 4 preliminary design options enabled an expansion of the gallery space while also retaining Anzac Hall.

The Memorial has now acknowledged that the ‘proposed works include the demolition of Anzac Hall which embodies part of the aesthetic values of the place; this is a significant negative impact and the most detrimental aspect of the proposal.’

The Heritage Impact Assessment that DAWE required the Memorial to commission found that the ‘loss of the existing ANZAC Hall is a sole significant loss of value and has a substantial negative impact on the heritage significance of the place.’

Both the Australian National Audit Office’s recent audit of EPBC Act assessments and the findings of the interim report of the Independent Review of the EPBC Act were critical of the framework’s effectiveness.

“It is disappointing that the government has already rejected[1] one of the review’s key recommendations to have ‘a strong, independent cop on the beat’[2] when this is so clearly required,” Ms Cousins said.

“The final review, due to be handed down at the end of this month means that attention will remain focussed on the reform opportunities and how EPBC Act assessments are being conducted in the interim.

“We urge the Minister to have the current EPBC referral withdrawn with instructions to pursue alternative solutions that meet both the current and future needs of the Memorial while also preserving its physical and social heritage values.

“In the face of widespread concern the Memorial’s executive seem to be just digging in their heels and reverse engineering consultation outcomes rather than taking on board legitimate concerns and amending their proposal.

“The Memorial has legislative obligations for the protection and conservation of its heritage values for all Australians. We appreciate there may be a need to increase the Memorial’s capacity, including some expansion, but we oppose doing this in a way that is wasteful, destructive, and damaging to the heritage value and integrity of the site.

“We fully support the goal of enhancing the memorial and better commemorating our servicemen and women, all we are asking is that it be done in the right way.”

Sarah Buckley

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