Heritage Guardians submission to National Capital Authority consultation on War Memorial Main Works approval application

The Heritage Guardians submission has now been posted: here and scroll down a bit to ‘David Stephens and Heritage Guardians’. Unfortunately, the website format scrubs out emphases so we’ve printed the original below. Recognising that the National Capital Authority’s remit is to assess whether the War Memorial project is inconsistent with the National Capital Plan, we have concentrated in the submission on areas of inconsistency with the Plan. There are lots of them.

The format also tries to channel submitters into commenting on the three ‘Main Works Packages’. This means there is repetition when general remarks apply to more than one Package. The most succinct general remark about the War Memorial development, though not used here, is that this is, and always has been, an unnecessary, expensive and vainglorious project. Heritage Guardians campaign diary.

The Heritage Guardians submission makes this crucial point about this current, final stage of the process:

A process as flawed as this NCA consultation has been detracts from Canberra’s status as the symbol of Australian national life and values, which is a key matter of national significance that the National Capital Plan is meant to protect. It has reduced national planning to a matter of logrolling, of responding to the loudest noise and the slickest spruiking. Canberra deserves better than this farce.

We recommend also submissions by Tim Hollo, Douglas Newton, Richard Llewellyn, Steve Flora, Sue Wareham, Penleigh Boyd, James Windeyer and Peter Stanley.

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Heritage Guardians submission

Main Works Package 1: New Southern Entrance

  1. The NCA must not approve this Package. The Package fails to conserve and enhance the significance of the Memorial as part of Canberra, so it is inconsistent with the National Capital Plan. Further, the Package trashes Canberra as the symbol of Australian national life and values – an important element of the Plan.
  2. The NCA works approval process sets an extremely low bar. The National Capital Plan contains general policy statements. It has been easy in the past for the Authority to find that specific project plans like the Memorial’s are not inconsistent with these policy statements. For their part, project proponents have been able to ‘drive a truck through’ the process, assisted by political pressure on the Authority where large projects like the Memorial redevelopment are involved.
  3. Nevertheless, there are elements of this Package that are clearly inconsistent with the Plan. First, the Plan is replete with references to the preservation of heritage: see particularly under ‘2.4 Liveability’ and its principles for ‘urban design and heritage’. The ‘key matters of national significance’, listed at the head of the NCA’s website entry on the Plan, and at which the Plan is directed, all relate to heritage, broadly defined.
  4. Regarding the New Southern Entrance, the government’s principal heritage advisers, the Australian Heritage Council, said in December 2019 that ‘[t]he works to the Southern Entrance of the War Memorial as currently conceived will detrimentally impact both the original fabric of the building and the experience of visitors who now enter the building through the inspiring entrance to the memorial spaces, as designed by the original architects’. That is a clear impact on heritage and is inconsistent with the Plan.
  5. In July 2020 in a submission to the Memorial, the Council made its concerns even clearer, stating that it ‘cannot support the conclusion that the proposed redevelopment will not have a serious impact on the listed heritage values of the site’. That is a crucial piece of evidence in assessing inconsistency with the Plan.
  6. As late as September 2020, the Historic Heritage Section (HHS) within the Environment Department had the Southern Entrance works in mind – as well as the other expanded exhibition areas – when it argued that ‘heritage values will be impacted by the addition of several large new spaces which will be focused primarily on exhibition of collections, visitor services and functions and events. In this arrangement, the original building’s significance is reduced, as is the significance of the commemorative spaces.’ HHS clearly saw the clash with heritage values, a clash that is inconsistent with the National Capital Plan.
  7. The Memorial’s Director has claimed that the façade of the Memorial will be ‘unchanged’ by the works, yet aerial shots and the Memorial’s own ‘before’ and ‘after’ pictures clearly reveal the extent of change, with the new work and the bladed wall on either side of the new entrance extending well into the existing forecourt. To say the Memorial’s façade will be unchanged is like saying the façade of my house will be unchanged by my adding a second storey. (See the pictures below.) Here again, there is heritage impact and inconsistency with the Plan.
  8. The NCA has repeated the Memorial’s misrepresentation. The Authority’s summary of Main Works Package 1 claims that ‘[t]he original Commemorative Forecourt, stairs and heritage entrance will be reinstated as they appear now with the addition of an oculus to the Entry Hall below’. The words ‘as they appear now’ are quite wrong.
  9. The National Capital Plan also says that ‘[s]ubstantial works of architecture, engineering and landscape within the Territory should be designed to contribute positively to the overall composition, symbolism and dignity of the National Capital’. Yet, the change in the Memorial’s main entrance, from one that brings the visitor up the stairs directly into line of sight with the Memorial’s commemorative heart, to one that is essentially an underground cavern reminiscent of the arrivals hall of Seoul Airport, dramatically changes the visitor experience.
  10. The new arrivals area will detract, in the words of the National Capital Plan, from the ‘symbolism and dignity of the National Capital’. It is all about grandeur and glory rather than remembrance and loss. Above it, the incongruous Oculus, and the intrusion of the Glazed Link over the roofline of the heritage building, further detract from the Memorial’s dignity and from the dignity of the National Capital. All these features are inconsistent with the Plan.
  11. Moving further out from the new entrance, the destruction of dozens of trees, some of them older than the Memorial itself, will sever the link the Memorial has with Mount Ainslie and damage the reflective solemn atmosphere of the area. Felling these trees to facilitate Main Works Package 1 does not conserve and enhance, in the words of the Plan, ‘landscape features which give the National Capital its character and setting, and which contribute to the integration of natural and urban environments’. Again, there is blatant inconsistency with the Plan.
  12. The treatment of the trees is also inconsistent with these words in the Plan:
  • ‘Retain the distinct urban form for which Canberra is well known, of a city within bush surrounds.’
  • ‘Protect the nationally significant open-space network, visual backdrop and landscape setting of the National Capital.’
  • ‘Ensure the development of a city that both respects environmental values and reflects national concerns with the sustainability of Australia’s urban areas.’
  1. More generally, the New Southern Entrance works will see an imbalance created in the landscape by the overdevelopment of the Memorial building in relation to the site as a whole. The symbolic isolation of the building will be diminished as the bricks and mortar spread. This will also affect the vista up and down Anzac Parade, with the Oculus and the bladed wall being particularly intrusive, adding to the inconsistency with the Plan.
  2. The increased bulk of the extended building on the Campbell site is inconsistent with these ‘key matters of national significance’ which the Plan is supposed to protect:
  • ‘Conservation and enhancement of the landscape features which give the National Capital its character and setting, and which contribute to the integration of natural and urban environments.’
  • ‘Respect for the key elements of the Griffins’ formally adopted plan for Canberra.’
  • ‘Creation, conservation and enhancement of fitting sites, approaches and backdrops for national institutions and ceremonies as well as National Capital uses.’
  1. Closer to Limestone Avenue, modifications are proposed to the existing parade ground, allegedly to harmonise the form of the area to better suit the existing grid geometry of the Main Building and improve sight lines to the Stone of Remembrance. More mundanely, and in the words of the Memorial Director at the NCA’s information session on 10 August, the parade ground will change from chisel-shaped to rectangular. This, the Director said, will make it easier for Australian Defence Force personnel to march up and down on ceremonial occasions. That may be a benefit for directionally challenged service people, but it is difficult to see how it advances the objectives of the National Capital Plan.
  2. Finally, a process as flawed as this NCA consultation has been detracts from Canberra’s status as the symbol of Australian national life and values, which is a key matter of national significance that the National Capital Plan is meant to protect. It has reduced national planning to a matter of logrolling, of responding to the loudest noise and the slickest spruiking. Canberra deserves better than this farce.

Before and after pictures from the Memorial’s documentation

Main Works Package 2: Bean Building Extension and Central Energy Plant

  1. The NCA must not approve this Package. The Package fails to conserve and enhance the significance of the Memorial as part of Canberra, so it is inconsistent with the National Capital Plan. Further, the Package trashes Canberra as the symbol of Australian national life and values – an important element of the Plan.
  2. The NCA works approval process sets an extremely low bar. The National Capital Plan contains general policy statements. It has been easy in the past for the Authority to find that specific project plans like the Memorial’s are not inconsistent with these policy statements. For their part, project proponents have been able to ‘drive a truck through’ the process, assisted by political pressure on the Authority where large projects like the Memorial redevelopment are involved.
  3. Nevertheless, there are elements of this Package that are clearly inconsistent with the Plan. First, the Plan is replete with references to the preservation of heritage: see particularly under ‘2.4 Liveability’ and its principles for ‘urban design and heritage’. The ‘key matters of national significance’, listed at the head of the NCA’s website entry on the Plan, and at which the Plan is directed, all relate to heritage, broadly defined.
  4. The attraction of the Memorial for 80 years has arisen from its careful balancing of the functions of memorial, museum, and repository of records. This balance has been central to the Memorial’s heritage value, its unique position in the world, and how it serves the values in the National Capital Plan. That attraction will dissipate if the balance is lost. This development threatens to trash that balance and for that reason alone it is inconsistent with the Plan.
  5. While, prima facie, the Bean Building extension is attractive because it enhances the Memorial’s records and research function, the extension is intimately connected with the expansion of the gallery space in the main building. The Bean Building needs to be extended to provide research facilities because of the conversion of the former research area in the original building into gallery space as the grandiose Glazed Link and new Anzac Hall take shape. Elephantiasis of the museum or entertainment function of the Memorial, following the failure to make difficult decisions about the use of existing space, has created the need to find research space elsewhere.
  6. More generally, the Bean Building works will see an imbalance created in the landscape by the overdevelopment of the Memorial building in relation to the site as a whole. The symbolic isolation of the building will be diminished as the bricks and mortar spread.
  7. The increased bulk of the extended Bean Building on the Campbell site is inconsistent with these ‘key matters of national significance’ which the Plan is supposed to protect:
  • ‘Conservation and enhancement of the landscape features which give the National Capital its character and setting, and which contribute to the integration of natural and urban environments.’
  • ‘Respect for the key elements of the Griffins’ formally adopted plan for Canberra.’
  • ‘Creation, conservation and enhancement of fitting sites, approaches and backdrops for national institutions and ceremonies as well as National Capital uses.’
  1. The Australian Heritage Council made telling points in this regard in its July 2020 submission to the Memorial, explicitly including the Bean Building extension among the elements of the project that had negative impacts on national heritage values and that distorted the balance on the site between landscape and bricks and mortar.
  2. The felling of trees to facilitate Main Works Package 2 does not conserve and enhance, in the words of the Plan, ‘landscape features which give the National Capital its character and setting, and which contribute to the integration of natural and urban environments’. There is blatant inconsistency here.
  3. The treatment of the trees is inconsistent also with these words in the Plan:
  • ‘Retain the distinct urban form for which Canberra is well known, of a city within bush surrounds.’
  • ‘Protect the nationally significant open-space network, visual backdrop and landscape setting of the National Capital.’
  • ‘Ensure the development of a city that both respects environmental values and reflects national concerns with the sustainability of Australia’s urban areas.’
  1. Finally, a process as flawed as this NCA consultation has been detracts from Canberra’s status as the symbol of Australian national life and values, which is a key matter of national significance that the National Capital Plan is meant to protect. It has reduced national planning to a matter of logrolling, of responding to the loudest noise and the slickest spruiking. Canberra deserves better than this farce.

Main Works Package 3: Anzac Hall and Glazed Link

  1. The NCA must not approve this Package. The Package fails to conserve and enhance the significance of the Memorial as part of Canberra, so it is inconsistent with the National Capital Plan. Further, the Package trashes Canberra as the symbol of Australian national life and values – an important element of the Plan.
  2. The NCA works approval process sets an extremely low bar. The National Capital Plan contains general policy statements. It has been easy in the past for the Authority to find that specific project plans like the Memorial’s are not inconsistent with these policy statements. For their part, project proponents have been able to ‘drive a truck through’ the process, assisted by political pressure on the Authority where large projects like the Memorial redevelopment are involved.
  3. Nevertheless, there are elements of this Package that are clearly inconsistent with the Plan. First, the Plan is replete with references to the preservation of heritage: see particularly under ‘2.4 Liveability’ and its principles for ‘urban design and heritage’. The ‘key matters of national significance’, listed at the head of the NCA’s website entry on the Plan, and at which the Plan is directed, all relate to heritage, broadly defined.
  4. The Australian Heritage Council said this in December 2019:

The demolition of Anzac Hall will remove a significant contributory element of the identified heritage values. In combination, and as acknowledged in the referral documentation, there is likely to be a significant negative impact on the heritage values of this outstanding Australian heritage place.

  1. In July 2020, the Council said this:

Physical expansion to support the display of large objects such as submarines and aircraft is not a sustainable intent over the long term and, in the current circumstances, cannot be achieved without significantly impacting listed heritage values.

  1. The Council’s remarks draw out the inconsistency with the following statement in the Plan:

Substantial works of architecture, engineering and landscape within the Territory should be designed to contribute positively to the overall composition, symbolism, and dignity of the National Capital.

  1. The NCA’s summary of Main Works Package 3 on the webpage for the August information sessions tells us that ‘[t]he proposed Anzac Hall will double the area available behind the Main Building for display of large objects that form part of the AWM’s collection, and which are currently unable to be viewed by the public’. Like the Memorial’s spruiking of the project over many years, this glib statement slides away from the fact that most cultural institutions in the world can display only 5-10 per cent of their collection at any one time. Why should the Memorial be different?
  2. And what objects are we talking about here? It is clear from numerous pieces of evidence – the Memorial’s submission to the Public Works Committee, its Final Preliminary Documentation to the Environment Department, statements by successive Directors, promotional videos, the Memorial’s current website – that the new two-level Anzac Hall and the Glazed Link are primarily intended to display an enlarged collection of Large Technology Objects, the machines and weapons of war. The new space will also accommodate guests – including arms company donors to the Memorial – at functions assiduously promoted by the Memorial’s catering contractors (a process that began in July 2019, long before all necessary approvals for the redevelopment had been received).
  3. The New Anzac Hall and the Glazed Link are glaring examples of how the Memorial project is inconsistent with the key matters of national significance which the Plan is supposed to protect, particularly the ‘[c]reation, conservation and enhancement of fitting sites, approaches and backdrops for national institutions and ceremonies as well as National Capital uses’. And these new constructions threaten those key matters only because of the destruction of the existing buildings, which in itself trashes those national values of which Canberra is supposed to be the symbol.
  4. The Plan also says, under the heading of ‘Sustainability’, that ‘[t]he natural environment of Canberra and the Territory will be protected and improved by reducing resource consumption and waste’. The destruction of Anzac Hall after just 20 years, when it was still in constant use and visited by thousands of people daily, is clearly inconsistent with this statement in the Plan.
  5. More generally, the Anzac Hall and Glazed Link works will see an imbalance created in the landscape by the overdevelopment of the Memorial building in relation to the site as a whole. The symbolic isolation of the building will be diminished as the bricks and mortar spread. This will also affect the vista up and down Anzac Parade, with the Oculus and the bladed wall being particularly intrusive.
  6. The increased bulk of the extended building on the Campbell site is inconsistent with these ‘key matters of national significance’ which the Plan is supposed to protect:
  • Conservation and enhancement of the landscape features which give the National Capital its character and setting, and which contribute to the integration of natural and urban environments.’
  • ‘Respect for the key elements of the Griffins’ formally adopted plan for Canberra.’
  • ‘Creation, conservation and enhancement of fitting sites, approaches and backdrops for national institutions and ceremonies as well as National Capital uses.’
  1. The felling of trees to facilitate Main Works Package 3 does not conserve and enhance, in the words of the Plan, ‘landscape features which give the National Capital its character and setting, and which contribute to the integration of natural and urban environments’. There is blatant inconsistency here.
  2. The treatment of the trees is inconsistent also with these words in the Plan:
  • ‘Retain the distinct urban form for which Canberra is well known, of a city within bush surrounds.’
  • ‘Protect the nationally significant open-space network, visual backdrop and landscape setting of the National Capital.’
  • ‘Ensure the development of a city that both respects environmental values and reflects national concerns with the sustainability of Australia’s urban areas.’
  1. Finally, a process as flawed as this NCA consultation has been detracts from Canberra’s status as the symbol of Australian national life and values, which is a key matter of national significance that the National Capital Plan is meant to protect. It has reduced national planning to a matter of logrolling, of responding to the loudest noise and the slickest spruiking. Canberra deserves better than this farce.

David Stephens

Convener, Heritage Guardians

 

 

 

 

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