Submission on 
Conservation of Australia’s Historic Heritage Places, Productivity Commission Draft Report
 
Paul Adam

The Draft Report raises important issues, and the final report has the potential to lead to major changes to policy and practice by all levels of government. It is unfortunate therefore that the Draft Report is such a disappointing document. The report reads as three separate components – the report text, findings and recommendations – with the linking logic which would lead from one to the other being difficult to discern. I would hope that in the final version there is a more explicit justification of the recommendations.

The need for education
The draft report highlights the need for education, in two different regards.

Firstly there is clearly a need for the various levels of government, and other agencies/bodies involved to make greater efforts to explain the processes and practices of heritage listings and their consequences.  It is clear that there are many deficiencies in currently available material, and also that the various levels of government are not always on the same wavelength.  (While I readily accept that there are genuine cases where property owners are taken by surprise by heritage matters, I also suspect that in the case of some developers there is an element of wilful ignorance).

Secondly there needs to be more public discussion on the importance and value of heritage, hopefully leading to a greater understanding and acceptance of the need for heritage conservation.  (Material presented to stimulate the discussion will need to be carefully prepared to avoid being dictatorial propaganda and also to be more than monocultural.  Existing heritage listings cover places from a range of cultures, but in general interpreted through a anglo-celtic paradigm.  There are listings, for example, of items related to the Chinese in Australia, but what does the Chinese community itself regard as its important heritage?  What is, or will be, important to the many more recent cultural and ethnic groups?)

Chapter 2 of the Draft report discusses the values of heritage and the case for heritage conservation, and this material could form the basis for developing educative resources.

Availability of data
The draft report emphasises the paucity of data on many issues relevant to the Inquiry, and the difficulty of compiling what ought to be straight forward statistics on matters, such as expenditure by government agencies on heritage.  When it comes to the contentious issue of the cost imposition on private landholders much of the evidence is anecdotal.

Given the paucity of hard evidence, it would have been preferable to have extended the preliminary phase of the inquiry, by commissioning the necessary research. To proceed to recommendation on the existing flimsy basis,will result in outcomes with little credibility.

I do not doubt that landholders believe that heritage listing may have cost them, directly or indirectly, ‘x’ dollars, and undoubtedly there are cases where costs will have been incurred.  Nevertheless has the Commission been able to obtain independent verification of some of the claims made?

There are passing references to the situation in overseas jurisdictions but little detailed analysis.  In particular, has the model favoured by the Commission been adopted previously anywhere in the world?

The scope of historic places
The expansion of the scope of historic places to include more than just buildings and structures is welcomed.

The reference to physically – created landscapes appears to be restricted to spatially constrained areas (such as the examples given of fishing areas, mining sites and saw pits) rather than the wider cultural landscape.  (There is a mention on p17 of the loss of cultural landscapes, but it is unclear whether cultural landscapes are included within the Commission’s concept of historic landscapes).  Cultural landscapes, where the spatial scale and intensity of human activity contribute to the sense of place, have been an important part of heritage conservation in Britain and Europe, but have been given less attention in Australia.  The specific REP provisions for the Jamberoo Valley in NSW represent an attempt to conserve a cultural landscape, and I suspect that public concern of the nature of development in particular regions may lead to more interest in landscape conservation.  Regions like the Jamberoo Valley (and examples in the UK of the National Parks such as the Lake and Peak districts) are places where a planning approach is required to a relatively large area, but all historic places occur in a spatial context, and a narrow, shrink wrapping, approach to defining sites of concern is likely to result in substantial loss in heritage values.  In some cases cadastral property boundaries may define the curtilage of heritage properties, but in other cases a wider sphere of influence will need to be defined to capture the links between a property and its surrounds.

The hierarchical model
The report strongly endorses a hierarchical model of heritage significance, and the principle of subsidiary which flows from the model.  While I can understand why this model gains the Commission’s support, in my opinion the model has the potential to lead to a substantial loss of heritage values.

The model implies that the heritage value of each site or property can be assessed on an absolute scale in isolation.  I would suggest that this narrowly reductionist approach will not capture the emergent properties that arise when the aggregate value of sites is considered.

The values of historic connectivity and sense of belonging that are discussed in chapter 2 rarely reside in single properties taken in isolation – even with grand public buildings their value is enhanced by their relation to each other, and to other buildings and spaces which under the hierarchical model would not individually be accorded significance.

The overall national heritage – that which gives us a sense of what we are and how we go there, is made up, like a jigsaw, of many individual piece