Stephens, David: National Capital Authority waves through Works Approval application for War Memorial carpark that is not – or is – part of the big $500m project

David Stephens*

‘National Capital Authority waves through Works Approval application for War Memorial carpark that is not – or is – part of the big $500m project’, Honest History, 23 November 2019

“When I use a word,” Humpty Dumpty said, in rather a scornful tone, “it means just what I choose it to mean – neither more nor less.”

“The question is,” said Alice, “whether you can make words mean so many different things.”

“The question is,” said Humpty Dumpty, “which is to be master – that’s all.” (Lewis Carroll, Through the Looking Glass)

Like Humpty Dumpty, public authorities have a way with words. When the National Capital Authority began the public consultation on the Australian War Memorial’s Works Approval application for carparking, the Authority’s website summarised the works as follows:

The National Capital Authority (NCA) has received a Works Approval application for the extension of Poppy’s Café Carpark and installation of a temporary carpark at Block 3 Section 39 Campbell.

The Australian Government has committed $498 million over 10 years towards the expansion of gallery spaces and improvement and modernisation of Australian War Memorial (AWM) buildings. This Works Approval is the first of the permanent works forming part of the broader redevelopment project.

Seems fairly clear: two carparks as part of a big redevelopment project. Yet, not so clear after all, apparently, as the Authority says in its report on the consultation, but we’ll get to that in a moment.

The Authority’s conclusion was spare, sticking closely to the Authority’s role:

The NCA’s consultation process was carried out in accordance with the National Capital Plan and the NCA’s Commitment to Community Engagement.    The NCA has reviewed the proposal and is satisfied that the concerns of the community have been  taken account of.  The NCA notes that the temporary carpark will be transformed into an open landscape area with  tree planting once the redevelopment project is completed. This will be subject to a separate works  approval.  The AWM has advised that 20 new trees will be planted within the Eastern Precinct as part of  the carpark extension project.  The proposal is  not inconsistent with the provisions of the National Capital Plan, and is supported  by the NCA. (Emphasis added)

So, waved through. More significant, though, were the Authority’s responses to the 22 public submissions it received. These submissions came from, among others, Major General Steve Gower, former Director of the Memorial, the Australian Institute of Architects, the present author on behalf of Heritage Guardians, Stewart Mitchell, former senior officer at the Memorial, Eric Martin on behalf of the National Trust of Australia, Ray Edmondson, former Arts bureaucrat, Professor Peter Stanley, Dr Margaret Beavis, former President, Medical Association for Prevention of War, and Tony Kevin, former Australian diplomat.

The consultation report summarised the submissions at length, noting they all ‘raised issues or objections in relation to elements of the proposal or the whole proposal’ and that they covered the removal of trees, the lack of a revegetation plan, the lack of a heritage referral, the lack of justification for on-site visitor parking, moral rights obligations, inconsistency with the Memorial’s Heritage Management Plan, and concern that temporary fencing had been erected in advance of the approval. Again, more significant was that a key issue mentioned by the Authority as just one of eight issues – ‘The works approval for the carpark extension is being considered separately from the AWM redevelopment proposal’ – was mentioned by 18 of the 22 submissions.

The Authority mostly summarised this frequently expressed objection as follows: ‘The submission expressed concern that the carpark is to be approved before the redevelopment project’. The Authority mostly responded to this objection thus:

The extension of the carpark is an independent structure [in a couple of renderings, ‘a standalone project’], not physically connected to the larger redevelopment project and is therefore able to be considered as a separate project. The extension of the carpark does not prejudice the NCA’s consideration of future works approvals associated with the redevelopment of the AWM.

Let’s put those two statements side by side. The NCA’s consultation notice said this:

This Works Approval is the first of the permanent works forming part of the broader redevelopment project. (Emphasis added)

It probably needed the word ‘for’ after the word ‘is’ but the meaning is clear enough, as we said earlier: the carparks are part of the big $500 million project.

On the other hand, the Authority’s response to submissions said this:

The extension of the carpark is an independent structure, not physically connected to the larger redevelopment project and is therefore able to be considered as a separate project. (Emphasis added)

Again, the language is clumsy but it seems that lack of physical connection is enough to qualify the carpark as a separate project. Even this lack is debatable when, for example, the carpark will only be metres from the proposed extension to the Bean Building, and workers using the temporary carpark will stroll from it to the excavations and constructions making up the main project. But to rely on alleged lack of physical connection is sophistry in extremis, when Blind Freddie knows – and the Memorial and the Authority admit – that the carparks would not be needed but for the main project. Humpty Dumpty would have loved this stuff.

As for the other part of the Authority’s response – ‘The extension of the carpark does not prejudice the NCA’s consideration of future works approvals associated with the redevelopment of the AWM’ – we’ll stick with the argument in the Heritage Guardians submission on the consultation: ‘approval of “salami slices” of the project helps make the overall project a fait accompli’. And that’s why the Memorial is doing it this way: its ‘salami slicing’ is gaming the approval process.

The National Capital Authority has been represented on the Interdepartmental Committee working on the War Memorial expansion project. The members of the Authority are listed here.

* David Stephens is editor of the Honest History website and a member of Heritage Guardians, co-ordinating a community campaign against the Memorial extensions.

 

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One comment on “Stephens, David: National Capital Authority waves through Works Approval application for War Memorial carpark that is not – or is – part of the big $500m project
  1. stewart says:

    It’s a very limited response from the NCA to obvious issues with the development. The most significant one is that the works approval for the carpark extension was considered separately from the overall AWM redevelopment project ie they have ignored the potential for cumulative impact. This is a fundamental issue with ongoing development of any site (and the NCA has actually raised this with the AWM in the past over incremental development at the AWM) but NCA has chosen in this instance to take the position “The carpark extension is a standalone project and is able to be considered separately to the larger AWM redevelopment”. One wonders why? This is quite an extraordinary position to take in considering heritage impact and does not align with my experience with the NCA or the majority of heritage practitioners. The AWM bypassed a heritage review by the Department of the Environment and Energy under Federal Heritage legislation (and that’s another issue) and it was left to the NCA to assess. I think they have got it badly wrong.

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