This document provides Save Braidwood’s views and comments on the Recommendations, page XLII of the Productivity Commission Draft Report into the Conservation of Australia’s Historic Heritage Places.

Our overall support for the Recommendations is based on the general thrust of the study to increase the understanding and status of heritage controls by:
•	Providing more transparency in the identification of heritage items by ensuring that they are identified using national standardized criteria that can be better understood, better focused on the truly important and less open to individual and arbitrary interpretation.
•	Providing owners of individual properties more input into the controls agreed to preserve those features of the property that meet the criteria, and those only.
•	Provide a more equitable funding and support mechanism, including compulsory purchase, to ameliorate the impact of those controls on individual owners.
•	Ensuring the ability to use an item in a way that is financially viable otherwise the item will be lost because its upkeep will be beyond the capacity of the owner.
•	Requiring heritage bodies with statutory responsibilities to focus on important sites and interact more positively and cooperatively with individual property owners.

Save Braidwood maintains that the current system as it has been applied in New South Wales together with the lack of effective consultation by the NSW Heritage Office has led to a severe reduction in the status of heritage conservation in the Braidwood community.  It is crucial that there be a cultural change in the NSW Heritage Office and Council if this damage is to be repaired.

Save Braidwood’s specific comments are in italics after each Recommendation

Recommendations 
The Commission’s key recommendation is as follows: 

DRAFT RECOMMENDATION 8.1 
Privately-owned properties should be included on a national, State, Territory, or 
local government statutory heritage list only after a negotiated conservation 
agreement has been entered into and should remain listed only while an 
agreement is in force. 

Save Braidwood strongly supports this recommendation.  It would ensure that the owners knew and understand the values that are proposed to be conserved and allow them to make informed decisions as to the use of their building.  In addition it would require the listing authority to be more rigorous in the application of the assessment prior to listing and remove the trivialization of the heritage conservation effort by the ‘blanket’ listing of items ‘just in case’ as seems to be the case with a number of the currently listed properties in Braidwood.  Then the funding of the agreed conservation would be easier to establish and justify from the owner’s point of view. The use of conservation agreements would remove one of the major impediments Braidwood has faced, that of the Heritage Office developing a conservation model for Braidwood without input from the owners of the item, namely the individual property owners and the community of Braidwood as a whole.

The following lists the recommendations in chapter order: 

3	Overview of historic heritage conservation in Australia 

DRAFT RECOMMENDATION 3.1 
All levels of government should put in place measures for collecting, maintaining 
and disseminating relevant data series on the conservation of Australia’s historic 
heritage places. 

Save Braidwood strongly supports this recommendation.  These data should include funds expended on such activities by government instrumentalities to privately owned items.

7	Assessing governments’ involvement  

DRAFT RECOMMENDATION 7.1 
The Australian Government should phase out the Register of the National Estate 
for historic heritage purposes, beginning with the closure of the Register to any 
new nominations.  
DRAFT RECOMMENDATION 7.2 
State and Territory governments should remove any reference to the Register of 
the National Estate from their planning and heritage legislation and regulations. 
DRAFT RECOMMENDATION 7.3 
Those State governments that have specific legislation governing the operations 
of the National Trust should repeal such legislation.  
 DRAFT RECOMMENDATION 7.4 
The Australian Government  should implement reporting systems that require 
government agencies with responsibility for historic heritage places to document 
and publicly report on the heritage  related costs associated with their 
conservation.  
DRAFT RECOMMENDATION 7.5 
State, Territory and local governments should: 
•  produce adequate conservation management plans for all government-owned 
statutory-listed properties; and  
•  implement reporting systems that require government agencies and local