The City of Melbourne has established an online database of well over 6000 heritage places which identifies each individual heritage place and provides significance assessment information. The consistency of data collection approaches across Australia could be best directed by the Commonwealth through further promotion and resourcing of the Australian Heritage Places Inventory. The online heritage inventory software utilised by the NSW Heritage Office and disseminated free to all NSW local councils provides a one stop public research resource. 

Draft Recommendation 7.1 – Phase out the Register of the National Estate (RNE)  

Draft Recommendation 7.2 – Remove any Reference to the RNE from heritage legislation. 	Supported. 
•	Many places listed on the Register of the National Estate are protected via statutory listing at the State or local level. Where places are listed on the Register of the National Estate but no other statutory list, the Commonwealth should refer nominations for assessment to the appropriate level of government (state or local). This should be a Commonwealth project managed by the Australian Heritage Commission as part of the process of phasing out the Register. It should be recognised that the Register of the National Estate, as a long running and national list, has significant community support. 
	
Draft Recommendation 7.3 – State governments should repeal legislation (where relevant) governing the operations of the Trust. 	•	There is no specific enabling legislation for the Trust in Victoria. However, the City of Melbourne supports the work of the National Trust as the key Australian community heritage organisation. The Trust, as noted by the Commission, is currently reviewing its activities and governance nationally.  The work of heritage conservation volunteers should be recognized and celebrated. 	
Draft Recommendation 7.4  - Government agencies should report on heritage related costs of conservation. 

	Supported
•	Government should lead by example in heritage conservation.  In NSW, state government departments have specific responsibilities under the Heritage Act 1977 (NSW). Section 170 requires government agencies to report on the identification, management and conservation of assets which have heritage significance.  The Commonwealth State of the Environment Reporting provides an existing mechanism for reporting on the condition of our cultural heritage. In terms of the costs of maintaining public heritage buildings, costs may depend on whether there is a maintenance backlog that must be recovered (and the costs of specialist trades to repair traditional fabric). Once a heritage building is restored, the cost of maintenance should be similar to any other building. The costs of conservation should not be included in listing criteria.	

Recommendation 7.5 -  All levels of government should prepare conservation management plans for government owned statutory listed places.  	•	The City of Melbourne regularly prepares Conservation Management Plans for heritage precincts such as parks and gardens.  A Conservation Management Plan is one management tool to assist the conservation of an identified place and enables customised and site specific controls through an agreed plan. They are a useful risk management tool for owner’s to have a strategic document to guide the conservation and development of heritage places. It may not be necessary to produce conservation management plans for all items, this should be dictated by the significance of the place and complexity of the issues.  	
Draft Recommendation 9.1 –  Negotiated conservation agreement made prior to private property heritage listing on the National Heritage List. Listing only in force during life of agreement.

Draft Recommendation 9.2 - Negotiated conservation agreement made prior to private property heritage listing on State level heritage lists.  Listing only in force during life of agreement.

Draft Recommendation 9.3 – State governments should require local government to negotiate conservation agreements prior to private property heritage listing.  Listing only in force during life of agreement.

	Not supported.
•	See response to 8.1	
Draft Recommendation 9.4 – State governments should enable local government to compulsorily acquire private property where only cost effective way to conserve. 	•	The Commonwealth government should investigate a range of assistance via a grants program to support heritage conservation which may include property acquisition. 
	
Draft Recommendation 9.5 -  Negotiated conservation agreement made prior to heritage listing of private property.  Listing only in force during life of agreement.	Not supported.  Refer earlier discussion on 8.1	
Draft Recommendation 9.6 – Where private property already listed and subsequently sold, agreement runs with land but may be renegotiated at the time of any substantive development application. 	Not supported. 
•	Linking a proposed management tool (via a conservation agreement) with heritage listing reverses the long standing international heritage conservation standard of separating the identification of heritage (listing) from management decisions.  The intended result could be far fewer listings and a loss of our irreplaceable heritage.  Further undermining this successful standard is the suggestion that such an agreement would not run with the land but may be re-negotiated with each subsequent owner (point of sale being the most difficult time to negotiate such an agreement) and at any time there was ‘substantive development’.  	
Draft Recommendation 9.7 -  Remove legislated ability to take heritage considerations into account in relation to individual property excepting where relate to heritage areas/precincts. 
Draft Recommendation 9.8 -  State governments should not list heritage areas or precincts on State registers.  To province of local government. 	Not supported. 
•	The State government has an important role in protecting State significant heritage including listing State significant heritage on the State Heritage Register. This is a clear and structured management and the participation of all levels of government ensures that all interests are served.  The Commonwealth government should take a leadership role in Australian cultural heritage management. Local government will always need the support of State governments to achieve  consistent and good decision making across municipal boundaries.