Stephens, David: War Memorial’s ‘Final Preliminary Documentation’ leaves many unanswered questions on $498m project: over to you, DAWE

David Stephens*

‘War Memorial’s “Final Preliminary Documentation” leaves many unanswered questions on $498m project: over to you, DAWE’, Honest History, 9 October 2020 updated

As foreshadowed in our posts of 30 September and 2 October, the Australian War Memorial has placed on its website its ‘Final Preliminary Documentation’ (FPD) regarding the consideration by the Department of Agriculture, Water and the Environment (DAWE) of how the $498m redevelopment project stacks up against the provisions of the Environment Protection and Biodiversity Conservation (EPBC) Act, particularly the parts relating to heritage matters. We can expect a DAWE decision within 40 business days – that is, by around the end of November – unless the Minister for the Environment, Sussan Ley MP, allows further time.

Meanwhile, the separate parliamentary Public Works Committee hearing into the project is nearing completion. The PWC will be seeking to report to the Parliament in roughly the same timeframe as the EPBC process.

This post does not claim to be a full analysis of the hundreds of pages of the Memorial’s FPD. The post instead looks mainly at some places where the Memorial’s plans have changed in response to the 167 public submissions it received, presents some statistics relating to those submissions, and – because Honest History and Heritage Guardians have long opposed this project – draws attention to some notable submissions against it. Most of the sources below are pdfs linked from the overview page on the Memorial’s website.

Minimal change: the juggernaut is mostly steady as she goes

The Memorial persists with the falsehood that its Act requires equitable treatment across wars

Heritage Guardians submission No. 143 to the Memorial said at paragraphs 2-7 that it was false to say that the Memorial’s Act required it to treat the stories of recent service on an ‘equitable basis’ with stories of earlier service. Our submission showed the ‘equitable basis’ concept derived, not from an Act of the Parliament, but from the Memorial’s internally generated Corporate Plans.

The Memorial’s Final Preliminary Documentation Submission at paragraph 3.1 persists with the equitable basis claim. It is still a furphy. As the Heritage Guardians submission said, ‘If the Memorial wants “equitable basis” to be in its Act, it should persuade the responsible Minister and the Parliament to make this happen’. Our submission went on (paragraph 10): ‘Heritage Guardians is not against recognition of service in recent wars and peacekeeping. It just believes that recognition should be provided within the Memorial’s existing space.’ Recognition should not be measured in floor space.

The Memorial’s minimal response to feedback fails to confront the big issues

The Memorial’s consultation on this project has been characterised by the tardy release of prolix and badly organised (but copiously illustrated) bundles of material. Beneath the paper onslaught, however, the main lines and much of the detail of the project have remained unaltered.

In its advice about the latest stage of consultation, the Memorial first refers us to Section 5 ‘Description of the Project’ in the Final Preliminary Documentation Submission. We are told that Sections 5.3.3 ‘New Southern Entrance’ and 5.4.4 ‘New Anzac Hall and Glazed Link’ contain ‘an especially useful summary of how the Memorial has responded to [public] feedback on these key design issues’.

Heritage Guardians submission No. 143 was strong on both the New Southern Entrance and Anzac Hall, so we were keen to see what had happened in these sections and in the related Attachments G and H to the Submission. On the entrance, the public (and DAWE) comments noted and responded to were on relatively trivial matters, such as the glazed lift (changes to detail and landscaping) and the profile of the oculus (a handrail is to be added).

More importantly, a central (and wrong) claim of earlier Memorial material – that the Memorial’s heritage facade will not be altered – is not mentioned in the FPD Submission, although the ‘before’ and ‘after’ illustrations at Figure 7.3 of the Submission (below) make it clear that the extent of alteration remains as before. Heritage Guardians’ arguments at paragraphs 23-27 of submission No. 143 still apply: the Memorial’s heritage facade will be greatly changed.

Picture1Turning to Anzac Hall, any change that does not include retention of this feature of the Memorial will be unsatisfactory to the nearly 1500 people who have said ‘Hands Off Anzac Hall’ on the architects’ petition and to the supporters of the Heritage Guardians campaign. Heritage Guardians’ submission No. 143 (paragraphs 19-22, 29-33) summarised arguments against the destruction of Anzac Hall.

Simply put, destroying Anzac Hall contradicts the Memorial’s own Heritage Management Plan and is, in the words of former Memorial Director, Major General Steve Gower, ‘a prize example of philistine vandalism masquerading as progress’. The changes set out in Section 7 of the FPD Submission do not mitigate this central fact.

The Memorial’s nominal commitments to future action provide small comfort

Handily, the Memorial lists, on pages 190-94 of Attachment C: Response to Public Submissions Report, 17 ‘Mitigation Strategies’ and 21 ‘Commitments’. With few exceptions, these undertakings fall into the categories of ‘prudent and predictable’ or ‘trivial and undemanding’ or both.

There are on the lists ‘Selection of Skilled Architects and Engineers’, ‘Quality in Design and Construction’, ‘Photographic Recording’, ‘National Capital Authority Approvals’, ‘Veterans and Defence Family Opportunity and Engagement Plan’, ‘Landscape Climate Advice’, ‘Future Galleries Content – Community Engagement’, and much more. As worthy as some of these undertakings are, they do not nearly counterbalance the grandiosity and hubris of the project taken as a whole.

Surely the Memorial can come up with more than this on why the project is needed?

Heritage Guardians submission No. 143 at paragraph 8 was critical of an earlier version of the Memorial’s documentation for offering less than two pages on ‘the need for the project’. The final version of the paperwork expands this to just 13 pages of text, mostly in Attachment E: Need for the Project, with a number of space calculations, plus dozens of pages of marginally relevant illustrations.

The argument, such as it is, hangs off the unsupportable ‘equitable basis’ claim at paragraph 3.1 of the Memorial’s Final Preliminary Documentation Submission (see above). These stories, the Submission asserts, ‘need to be told’ and the worth Australians will attribute to them is linked to the amount of space the Memorial devotes to them. Treating recent stories equitably, the assertion runs, requires building more space, rather than making difficult decisions to allocate existing space between competing subject matter, say, less space to Colonial Conflicts (forgotten wars and skirmishes pre-1901) and more to recent deployments (Afghanistan, Iraq, peacekeeping).

Submissions to the Memorial paid more attention to the ‘need’ question than the Memorial does. The Memorial’s own classification of the 167 submissions it received shows that ‘Key Theme: Need for the Project’ was mentioned in 67 submissions, second among EPBC-related themes and sub-themes only to ‘Key Theme: Heritage Impacts’, with 83 mentions.

Blurring the line between supporting service and supporting wars

There is another point in the documentation that deserves comment. At paragraph 2 of Attachment C: Response to Public Submissions Report these words appear:

This project will modernise and expand the galleries and buildings to enable the Memorial to tell the continuing story of Australia’s contemporary contribution to a better world through the eyes of those who have served in modern conflicts; connecting the spirit of our past, present, and future for generations to come. (Emphasis added.)

One of the dangers of portraying recent or current military operations at the Memorial is that such portrayal may anticipate or influence the historical verdict on these operations. Museology can be used to support politically controversial wars and warlike operations, especially while they are still under way or soon after.

In turn, political influence can corrupt the Memorial’s role. Visitors to the Memorial, including children, could come to – and be encouraged to – blur the distinction between support for those who served and support for the causes governments signed up to.

That support could easily extend to support for funding of the armaments and war machines deemed (by governments and defence forces) necessary to pursue these causes. The manufacturers of those armaments and machines are notable donors to the Memorial and their products are slated for prominent display in the extended space. (See Heritage Guardians submission to the Public Works Committee inquiry, paragraphs 18-24.)

Heritage Guardians and Honest History have often used the term ‘military-industrial-commemorative complex’ to describe the close links between government, the defence forces, defence manufacturers, and the War Memorial. Blurring the line between commemoration of service and support for wars threatens to strengthen those links. Language like that quoted above suggests the Memorial has already crossed that line.

Many Australians, including some of the men and women who served, would debate whether our involvement in Afghanistan, Iraq or Vietnam made a ‘contribution to a better world’ rather than, say, making ‘insurance’ down payments on the American alliance. The Memorial has glossed over such debate with a burst of PR spin.

Not all conflicts, past, present and future, can be treated equally. Recognition of recent wars and peacekeeping operations should be proportional to their significance in the overall history of the nation at war.

A Memorial properly serving the people would not be spinning about contributions to a better world but, instead, would be helping us ask and answer the important questions like ‘why did we get involved in this war?’ and ‘was it worth it?’

Some statistics: no sign of the Memorial’s boasted 80 per cent support

Who made submissions?

The Memorial received 167 submissions. There are two summary lists of them in the published material, at pages 1 and 2 of Preliminary Documentation Public Comment (hereafter ‘Comment’) and pages 187 to 189 of Attachment C: Response to Public Submissions Report.

Neither list includes authors but each submission is categorised: General Public (85 submissions), Architectural Community (10), Descendant [of a serviceman or woman] (19), Veterans Community (43), Contemporary Defence Family (two), Community Interest Groups (six), and Government (two). The Report list analyses comments against 18 themes and sub-themes, from ‘need for the project’, via design features, right through to ‘non-EPBC matters’.

The Memorial’s lists cover all 167 submissions, though it is only publishing submissions where authors agree to this – and not all of the authors have agreed to the inclusion of their names on published submissions. At the time of writing this article, 97 submissions had been published (in the Comment volume) and more may be published as permissions come in.

Pro and Con and Neutral

The Report list classifies the 167 submissions as ‘generally supportive’ and ‘generally not supportive’. There are 64 (38 per cent) shown as generally supportive, 97 (58 per cent) as generally not supportive, and the remaining six submissions (4 per cent) are mixed or neutral.

Heritage Guardians has no way of checking the Memorial’s judgements about support or opposition in unpublished submissions but we ran the numbers on the 97 published submissions and came up with the same results as the Memorial’s on those 97: generally supportive = 33 (34 per cent); generally non-supportive = 61 (63 per cent); neutral = three (3 per cent). So, the splits on published submissions are pretty much the same as on all submissions, although published submissions are less supportive (by ten per cent) than unpublished ones. We offer no idea why that is.

Not 80 per cent support, not by a country mile

The point is that less than 40 per cent of submissions generally supporting the Memorial project is way, way less than the Memorial’s persistent boast that around 80 per cent of Australians support it. (For more on the Memorial’s claims, see paras 35-54 of the Heritage Guardians submission No. 143 and project director Hitches to Senate Estimates, 4 March 2020, page 148 of the Hansard.)

Explaining the 80 per cent claim, Heritage Guardians argue that, if you show someone a glossy picture of a proposed development, accompanied with attractive rhetoric, and no hint of alternatives or context, most people will, of course, say, ‘Yes, you bet. What a great idea!’ That is what the Memorial has been doing for many months to get those high numbers.

Just as the gate was closing …

Finally, there is another interesting feature of the 167 submissions. They are listed chronologically by date of sending, with the first dated 2 July and the last in mid-August. Of the first 80 submissions received, only 13 (16 per cent) were classified ‘generally supportive’, but, of the next 87 received, 51 (64 per cent) were labelled generally supportive. These 87 submissions were sent and/or received close to the nominal deadline 0f 31 July. Again, we venture no reason for the differing splits among early and late submissions, though 37 of the 43 ‘Veterans Community’ submissions were among that late-arriving second 87, and 35 of them were ‘generally supportive’.

The arguments against in a selection of submissions – including one from the principal adviser to the Australian Government on heritage matters

Ten submissions summarising some of the main arguments

These submissions can be found sequentially by number in the Comment volume on the Memorial’s website.

  • Submission No. 15 from Max Bourke AM, retired Arts bureaucrat: ‘The AWM is a beautiful and quite adequate facility … This is just hubris from now on far beyond commemoration.’
  • Submission No. 20 from Elizabeth Evatt AC, former Chair of the Australian Law Reform Commission and former Chief Judge of the Family Court of Australia: ‘I am concerned that the proposed development will undermine the purpose of the AWM as I see it, namely to honour and commemorate the service of so many Australian men and women’.
  • Submission No. 34 from Penelope Seidler AM, architect and former member of the Council of the National Gallery of Australia: ‘It appears the new addition will house armaments, war machines and military paraphernalia whereas the purpose should remain with those who served our country rather than creating a military or War Museum’.
  • Submission No. 40 from Angela Woollacott, Manning Clark Professor of History, Australian National University: ‘It will be a real loss to the nation to forfeit an important and respected Memorial to a glitzy and militaristic Museum’.
  • Submission No. 58 from George Browning, former Anglican Bishop of Canberra and Goulburn: ‘Involvement in war is not the defining feature of Australia’s character and identity’.
  • Submission No. 78 from JB Windeyer, historian and retired teacher: ‘I would prioritise the funding of the other national collecting institutions which are having to cut staff and services’.
  • Submission No. 103 from Peter Watts AM, retired museum director, architect and landscape architect: ‘The proposal to demolish the ANZAC Hall is an obscene one … There must come a time when enough is enough.’
  • Submission No. 114 from Douglas Newton, historian: ‘The redevelopment project is a grandiose extravagance masquerading as red-poppy respect for the fallen and the returned servicemen and women’.
  • Submission No. 147 from Michael Piggott AM, retired archivist and Chairperson, (ACT) Territory Records Advisory Council: ‘None of the arguments for the development are so compelling or convincing that they demonstrate conclusively that only the specific development proposed (and no other alternative) must be supported’.

Australian Heritage Council submission

Perhaps the most significant of all the submissions, though, is No. 152 from the Australian Heritage Council, the government’s principal adviser on heritage matters. The submission is signed off by the Chair of the Council, former Liberal Cabinet Minister, Dr David Kemp AC. The submission says:

Regrettably the council cannot support the conclusion that the proposed redevelopment will not have a serious impact on the listed heritage values of the site and recommends that the matters above [set out in the Council’s submission] be given serious attention.

Among other points, the Council suggested that operational changes and better use of technology could more effectively use the existing footprint, without the need for larger exhibition spaces.

Given the official status of the Council, it is disturbing that only once, and then in passing, does the Memorial mention the Council’s concerns. Buried at Section 9.7.2 of Attachment C: Response to Public Submissions Report there is a note of the Council’s criticism of the Memorial’s lack of consideration of the impact of the Bean Building extension on the Memorial’s Eastern Precinct. More fundamental elements of the Council’s critique are ignored by the  Memorial.

Importantly, it seems that the Council, a government body, did not avail itself of the opportunity to have its submission remain private to the Memorial and DAWE, but agreed to its publication. Unlike the Memorial, whose record of public consultation on this project has been patchy to say the least, the Council was fully transparent.

Other submissions

Also among the submissions in the Comment volume are these: 111, from Queensland architects and heritage experts, Judith McKay and Don Watson; 113, from former Memorial Director Steve Gower; 127, from former Memorial officer, Stewart Mitchell; 137, from architect and heritage consultant, Geoff Ashley; 143, from Heritage Guardians; 144, from Medical Association for Prevention of War; 153, from the Australian Institute of Architects. Each of them deserves a close reading.

Conclusions: questions remaining

  • Why does the Memorial devote so little attention to establishing the ‘need’ for the project when need is clearly a major theme of the public submissions?
  • Who in government authorised the theme in the Memorial’s propaganda that all of our wars over time – not just all of our servicemen and women – should be treated equitably and that all of these wars are about making a contribution to a better world?
  • How can the Memorial continue to claim it has overwhelming public support for the project?
  • Why was there a sudden rush of ‘generally supportive’ submissions just as the Memorial’s deadline loomed?
  • How can the Memorial’s documentation take so little notice of the concerns of the Australian Heritage Council, the government’s principal adviser on heritage matters?

* David Stephens is editor of the Honest History website and convener of the Heritage Guardians community campaign against the Memorial project.

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