War Memorial $498m redevelopment project: accountability round-up – Public Works Committee and EPBC Act

Update 4 September 2020: Some clarification on stumbling War Memorial heritage process

Advice from the Department of Agriculture, Water and the Environment (DAWE), responsible for heritage, has made things clearer about the ‘privacy’ aspects below. Campaign diary, entry for 4 September.

Update 20 August 2020: Unhelpful list of commenters provided by War Memorial – but more to come

The Memorial has posted on its website (scroll down to the link to heading ‘Download EPBC Public Comment Listing (PDF file)) ‘a list of comment authors’, which turns out not be quite that but a list of 156 submissions marked ‘Personal submission’ plus 11 from organisations including Heritage Guardians, Medical Association for Prevention of War and the Australian Institute of Architects. The explanation for this unhelpful document – and next steps – is bolded in the following extracts from the Memorial’s website.

  • Stage 2 – Preliminary documentation revisions: We received 167 public comments including two (2) late submissions which have been accepted. A list of comment authors is provided at the link below, noting that personal submissions have not been disclosed at this time whilst privacy considerations are under review. We will review and consider the public comments received as well as any initial feedback from sources such as the Department of Agriculture, Water and Environment. This will inform any changes to our preliminary documentation, including updated design, mitigation measures or clarifications as required.
  • Stage 3 – Department of Agriculture, Water and Environment review: We intend to submit our revised preliminary documentation to the Department of Agriculture, Water and Environment late August/early September 2020. [Update 22 August: or ‘sometime in September’, according to later advice from the Memorial] The revised preliminary documentation, and the comments received, will also be published on our website at this time. The department then undertakes its own internal processes before making a final decision on our referral. A decision will then depend on Departmental processes and is expected no earlier than the end of October 2020. For further information on the referral process, please refer to the department’s website.


The word ‘accountability’ in this heading is used deliberately: in this project there has been too little of it and that too late. ‘[The Australian War Memorial] avoided scrutiny in the budget process, in an interdepartmental committee and in Senate estimates’, the author told the Public Works Committee (PWC) hearing on 14 July (page 1). ‘The memorial cut corners in the Department of Finance rules applying to capital works … It has ducked and weaved and dithered in consulting with the relevant departments on heritage matters.’

The PWC has advised that the number of submissions received for its inquiry into the Memorial redevelopment – 74 plus supplementary submissions – is the largest received for any PWC inquiry since the Committee’s inauguration in 1913. And more than three-quarters of the submissions have been against the Memorial project.

Notable among supplementary submissions – received since the public hearing – are Nos 40.1 from Heritage Guardians, 48.1 from Medical Association for Prevention of War, and 68.1 from the Australian Institute of Architects. Among other matters reiterated, these submissions take issue with careless and inaccurate evidence from the Memorial to the PWC, particularly regarding the consultation process as the project was being developed.

Some of the questions that should have been asked by elected representatives and government were asked instead in Heritage Guardians’ submission No. 40 to the PWC. The PWC put the questions to the Memorial and it has answered them in 256 pages of documentation, though most of the bulk is appendices previously published elsewhere.

Among the Memorial’s responses are its change of tack on whether the Memorial can provide a ‘therapeutic milieu’ for recent veterans, a defence of its approach to displaying Large Technology Objects, a repeat of the furphy that the spending on the build ‘does not come at the expense of investing in veterans’ services’ (the principle of opportunity cost being glossed over), avoidance of questions about the decision-making process (particularly regarding Anzac Hall), and repetition of the Memorial’s questionable claims about the degree of public support for the project. (On this last point, see Heritage Guardians’ EPBC submission.)

And then there is the heritage process under the Environment Protection and Biodiversity Conservation (EPBC) Act. The latest stage of this process asked people to provide comments to the Memorial on its ‘final preliminary documentation’ lodged with the Department of Agriculture, Water and the Environment, responsible for heritage matters under the EPBC Act.

The Memorial received 165 comments on the documentation, which meant it could not meet its own deadline of 10 August for publishing revised documentation on its website, along with comments received. Not for the first time, the Memorial has been flummoxed by the public reaction to its plans, although we do not yet know which way, pro or con, the comments fall.

The current plan is for a list of the 165 comment authors to be published very soon (probably tomorrow). Then, later, we’ll get the full text of comments, the Memorial’s summary of them, and any Memorial amendments to its documentation, at the same time as the documentation goes back to DAWE for its further action.

David Stephens

18 August 2020 updated

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