- Make a comment on the current Australian War Memorial Referral under Environment Protection and Biodiversity (EPBC) Act; comments close 13 December 2019 (Department of the Environment and Energy website Referral No. 2019/8574).
- Attend War Memorial consultations on a future Referral under EPBC Act; consultations 2-12 December 2019 (War Memorial media release of 3 December 2019; another link)
Salami slicing is something that old-fashioned delicatessens did with a wheel-shaped blade, though now those of us who like processed meat tend to buy it in vacuum-packed plastic. Salami slicing is also used, however, by project proponents wishing to game approval processes, such as those put in place by Australian legislation on planning and heritage matters.
Heritage Guardians said this in its submission to the National Capital Authority on the War Memorial’s Works Approval application for carparking associated with the Memorial’s $500 million expansion program:
[T]he Authority has been put in the position of having to consider an “early works” application for a multi-stage project where approval of the application inevitably has implications for the project as a whole. The term “salami slicing” could apply. The threshold questions are: 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 National Capital Authority duly waved the Memorial’s application through. To describe this outcome, we made use of Lewis Carroll’s Humpty Dumpty (‘”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”‘) to characterise the Authority’s decision: the Authority said the carparking ‘is the first of the permanent works forming part of the broader redevelopment project’ but it was, at the same time ‘an independent structure, not physically connected to the larger redevelopment project and is therefore able to be considered as a separate project’. So there: salami sliced and wrapped.
Another slice of salami is currently under consideration at the Department of the Environment and Energy (DEE), which has to decide whether some parts (slices) of the Memorial project – the New Southern Entrance, Anzac Hall, the Glazed Courtyard, and the Parliament House Vista – should be declared Controlled Actions under the EPBC Act. We know from the Memorial’s media release that the slice currently being considered by DEE (closing 13 December) is separate from the one the Memorial is consulting people on from 2 December (yesterday) to 12 December. This is because the latter consultation includes sections of the project which are not covered by the current Referral – refurbishment of the main building, an extension to the Bean Building, and public realm works – and because ‘data and feedback’ have to be collected to go to DEE as part of the consultation process. (Moreover, the current consultation was meant to close on 3 December, but the time had to be extended because some of the documentation was overlooked on the first go.)
Latest model salami slicing machine (Alibaba)
The links above will take you to where you can make your views known. The War Memorial media release includes contact details if you need clarification. We think we’ve got it right.
We will publish later in the week the Heritage Guardians submission on the current EPBC Referral. Meanwhile, here is a summary of the submission.
The proposal should be subject to rigorous assessment by the Department [of the Environment and Energy] as a controlled action under the EPBC Act.
National Heritage values and Commonwealth Heritage values are at risk of significant impact from the proposal as it relates to the New Southern Entrance, Anzac Hall, the Glazed Courtyard, and the Parliament House Vista.
There are whole of environment impacts also.
The Referral does not cover significant aspects of the project, contributing to ‘salami slicing’ of the project to an extent that amounts to gaming of the approvals process.
The Referral contains misleading or incorrect information in relation to the project’s Detailed Business Case, the basis for project costings, the Memorial’s description of its role, and the amount of consultation the Memorial has undertaken on the project.
3 December 2019 updated
David Stephens is a member of the Heritage Guardians committee, leading a community campaign against the extensions to the War Memorial.
The cumulative impact of new and future development is a critical consideration in heritage impact assessment and it really is outrageous how the AWM is approaching this. The NCA has made a significant mistake in not considering this for the carpark – it will be shocking if DEE does not simply throw this approach out the window it’s so bad!