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Heritage Guardians submission to National Capital Authority on War Memorial carpark deplores gaming of approval systems by ‘salami slicing’ projects

Heritage Guardians has made a submission to the National Capital Authority’s public consultation on the Australian War Memorial’s Works Approval application for carparking associated with the Memorial’s $498m expansion. The consultation closed on 5 November. Update 23 November 2019: The Authority’s decision.

The Heritage Guardians submission covers threshold questions, other procedural aspects, the role of the Department of the Environment and Energy, and the planning report, heritage impact statement and ecology report lodged with the Memorial’s application. The key point in the Heritage Guardians submission is that approvals of early stages of multi-stage projects inevitably help the whole project become a fait accompli. Proponents ‘salami slice’ projects into stages to achieve this outcome, effectively gaming the approvals system.

The threshold questions are [the submission says]: Is the Authority able to assess this part of the project in isolation from the entire project? How can approval for this application be taken as other than acceptance of the project as a whole?

The submission notes that the perception that the Memorial is somehow ‘sacred’ has influenced attitudes to it. The submission concludes:

In considering this application, the Authority has an opportunity to make a firm statement
supportive of accountability and probity and against the gaming of statutory processes by
the “salami slicing” of complex projects. It should do so. Such a statement would also
remind departments and agencies that projects – regardless of who proposes them – will
not be “waved through”.

Heritage Guardians is co-ordinating a community campaign against the Memorial expansion program. Earlier papers.

7 November 2019 updated