I appreciate the opportunity for public comment on this important issue. I was the Federal Shadow Minister for Environment and Heritage when the then Federal Minister for Environment and Heritage announced the move to nominate the Royal Exhibition Building and Carlton Gardens for World Heritage listing. I have followed the history of this site with considerable interest.
I am now, in a voluntary capacity, the Convenor of Planning Democracy, a network of resident action groups. Our principal concerns are the protection of heritage, the protection of tree canopy cover, the protection of open space, and giving residents a say in planning issues. The Friends of Royal Exhibition Building and Carlton Gardens, and Protectors of Public Lands Inc, are two of our supporter groups. I endorse the concerns they have expressed, and the comments they made, concerning this World Heritage site.
The UNESCO has extensive guidance documents on its public websites about how World Heritage sites should be managed so that they are effectively conserved and protected. These documents place community involvement at the forefront of decision making and management in ensuring the future of World Heritage sites.
However, neither the present management arrangements, nor those proposed, give effect to this policy (UNESCO Article 6 Policies regarding Communities, WH Committee, Strategic Objective 5). Therefore, I request that the Management Plan be expressly amended to include provision for community representation, making use of individuals with experience in community and heritage advocacy concerning the Royal Exhibition Building and Carlton Gardens.
The second key shortcoming of the World Heritage management Plan Draft is that it makes no provision for the establishment of an independent statutory authority to manage the site. The present management arrangements have failed. No-one has the World Heritage values of the site as their first priority. Everyone has other priorities. The fact that this lack of focus has failed is evident enough from Pages ix-xiv of the Executive Summary. They set out no fewer than 32 high priority actions as outstanding and necessary. If the existing system was working, this would not be the case. Unfortunately, there is nothing in the recommendations which gives any confidence that these actions will happen. There is still not the management or resources allocated to the site which will ensure that these actions take place.
A single central and independent World Heritage authority for the site is needed. Other Australian World Heritage sites, such as the Sydney Opera House and Port Arthur, have this. I am told that the Port Arthur governance arrangement could be quite readily adapted to the Royal Exhibition Building and Carlton Gardens. I request that the Committee examine this model and its applicability here. I understand that the Royal Exhibition Building and Carlton Gardens was managed by a Trust from 1879 until the late 1980s.
The third problem is that the Management Plan seems unlikely to change the present low-key approach taken to the World Heritage significance of the site. It does not present as a Melbourne icon, nor is it promoted as an international destination showcasing the Outstanding Universal Values that justified its UNESCO listing in the first place. We should aspire to have it given similar profile to other World Heritage sites. The Australian Government needs to have a more express role in the management, funding and resourcing of this site. This is necessary in order for the Australian Government to discharge the obligations that arise from its Agreement with UNESCO concerning the site. The Australian Government cannot delegate this responsibility to local authorities and hope they get it right. It needs to be directly involved both in management and in financing.
The fourth problem with the Plan is that it does not address the need to better protect the Buffer Zone. There is no doubt that permits given for high rise developments in the Buffer Zone since the World Heritage listing have damaged the values of the Royal Exhibition Building. One post-citation high rise development is 64 storeys high, unquestionably changing the context of the Building. If planning continues to proceed as if it is business as usual, without regard to the existence of a nearby World Heritage site, then over time the value of the site, and the listing, will gradually melt away. At some point the UNESCO may well decide that the damage is too great to be ignored, and remove the site’s listing. It has happened elsewhere.
I believe that the fragmentation and inconsistency in World Heritage related statutory decision making by different authorities would be improved if Heritage Victoria were made the referral and determining body for statutory planning applications for permits for proposed actions and developments in the Site and Buffer Zone. I request that the Plan be amended to reflect this. This would not change the requirement for referral under the EPBC Act for proposed actions and developments that may have an impact on the Outstanding Universal Values. There is considerable concern that the EPBC Act at present relies far too much on the honesty of project proponents to refer their plans for consideration. It would appear that the Act itself needs to be amended so that the Federal Department is obliged to investigate and respond to projects that are brought to its attention as potentially needing to be considered under the Act.
I hope it is not too late to establish a World Heritage Authority that has the powers, functions, and funding, to give this World Heritage site the standard of management and protection it deserves.
The Hon. Kelvin Thomson