The 3068 Group
PO Box 118
Clifton Hill VIC 3068
ABN: 61 907 325 331

THE 3068 GROUP INC

Mr. Neil Byron
Presiding Commissioner,
Enquiry into Conservation of Australia's Historic Heritage Place
Productivity Commission, PO Box 80
BELCONNEN ACT 2616

Submission from the 3068 Group
Productivity Commission Draft Report into Conservation of Australia's Historic Heritage Places http://www.pc.qov.au/inquirv/heritage/index.html

Thank you for the opportunity to make a submission in relation to the Productivity
Commission's Draft Report on the Conservation of Australia's Historic Heritage Places.

The 3068 Group represents residents in Clifton Hill and North Fitzroy who are committed to preserving our heritage, especially but not only the unique 19th Century environment preserved in the City of Yarra where we live.

We are profoundly concerned by the draft report's proposal to give inordinate power to the owner of a property to decide whether or not a place is culturally significant to the broader community.
We believe the commission has tried to accommodate the needs of owners of historic places
by treating them as stakeholders in the communities cultural heritage. However we submit that as owners they have a vested interest in the commercial value of the property that is in many cases not aligned with the protection of the cultural significance of place.

Owners, have the greatest commercial interest in the outcome of a proposal to alter an historic place. In the current environment, they can apply correspondingly greater resources to obtain the best expert heritage, planning and legal opinion to support their proposals. Owners can also apply these resources to any amendment to planning scheme heritage controls to ensure the amendment is favourable to their interests.

The decision of what is significant and what is not should continue to be determined by conservation experts guided by the Burra Charter or AHC criteria, and documentary evidence. These determinations are subject to both public and peer review and must be defended to panels against arguments put by the owner's experts. To allow the owner to vet these determinations would be contrary to the Burra charter.

The proposal overlooks the power imbalance in the owners favour. Negotiation outcomes depend on