The Adelaide Park Lands have been handed to the planning bureaucracy under the Development Act, which means there will not be any right of public appeal to the continuing corporatisation and commercialisation of our world heritage significant 
Park Lands.  This atrocious Act was rammed through the SA Parliament, on the 29th November 2005, the day before Parliament went on holiday until after the next election.

Has the Productivity Commission factored in the cost of the litigation that has already, and which will be greatly increased as a result of this?  The continuous cycle of PAR's; the Court time required to wade through reams of planning waffle and endless planning committee meetings; reports that no-one reads; planning bye-laws, advisory groups briefings, Ministerial briefings, and Cabinet briefings and media releases; council committee meetings, the public notification of all these  'strategies', must be costing the taxpayers a forturne.  The EPBC Act itself is 700 pages long.  It is absurd, ridiculous, time-wasting!  So many divided authorities that nothing ever gets done.  History proves it, and so does your report.

And each of the States have their very own version of these PPP's, i.e., the Plunder of Public Property authorities.  Every 3 years the 'broken wheel' will be re-invented by the next crop of delegated 'statutory' authorities; the next lot of consultants who try and impose their knowledge of other places legislation on the unsuspecting public of South Australia.  Whereas all that is required to protect the Adelaide Park Lands for future generations is an understanding and acknowledgement of the existing Acts and their legal status as a 'dedicated' trust of international significance.  An Independent Chartered Trust is the only constitutionally acceptable option which will protect them from Federal, State and Local Governments.
 
A new National Heritage policy is urgently required. 

 The Sydney Harbour Federation Trust Act looks like the most likely model that could be implemented nationally, simply because it has Section 71 removing interference from any other legislation & with on-going mandatory public involvement.

"In the Minister's opinion" ...must be removed from the current acts.  It should be replaced by a new national, constitutional definition of Crown Land, which restores the Sovereignty of public ownership of the land  under 'Responsible' Governments through Parliaments.  Delegated authorities are getting completely out of control.  Jobbery appears to be government policy.

I hope that the Prime Minister will call for a NEW ENQUIRY on Urban Renewal incorporating Historic Places as part of the compulsory teaching of Australian history and civics in schools.   I believe that one of the reasons for this enquiry was to 'tell Australia's stories'.

Regarding your 'RECOMMENDATIONS'. 
In a word - VISIONLESS.  Where are the PRO-ACTIVE ideas under points 5 & 6 of your brief?  Where is the BENEFIT analysis?  Cultural tourism values are virtually ignored.  No Australian stories here.

The advert for the National Heritage Investment Initiative grants programme of 3rd December 2005 offered $10.5 million, for the next 4 year investments to "restore and conserve Australia's most important historic heritage places.'  Priority will be given to places on the NHL.  Proposed works must be in accordance with a current approved management plan not more than five years old'.  Tenders closed 20 January 2006.

As heritage significance is all about comparative values, can you tell me what is the cost of the convoluted, non-cooperative, multi-duplicated, archaic system we have had for the past 13 years in SA, as compared to the plan adopted and implemented by the Blair government, administered by an autonomous English Heritage, funded by the Heritage Lottery Fund with massive support from the community? 

  I would refer you to a DEH tender for a Research Study to 'select places of outstanding heritage value to the nation relating to the theme of urban and town planning' closing on the 14 February 2006.  The study involves the preparation of a contextual history, development of an assessment methodology, a list of potentially significant places, assessment of 4-6 places, and the preparation of a creative communications strategy.'

I would invite members of the South Australian public to a free lecture and power-point presentation by Dr. Karen Cook, Special Collections Librarian, Kansas University,  Friday 24th February lunchtime at the Institute Building, Kintore Avenue.  Dr. Cook will be presenting her Australian Map Circle conference presentation  - "The Desired Blessing".  Thomas John Maslen and the Map in his Friend of Australia (London 1830).  Maslen was a key green spaces and town planning visionary involved in the founding of South Australia.  

Please consider this submission as my completely cost-free nomination titled - 'The Adelaide Park Lands & Colonel Light's Historic Plans for Adelaide,' for Australia's new ICON list.  An international bibliography and archive of historical primary source documents which will meet the ICOMOS World Heritage criteria for 'authenticity', can be supplied on request.