Points on cultural heritage for CIS submission
The proposed East West link will:
- destroy the remnant bushland in West Royal Park–the only area of this kind of vegetation left in Melbourne;
- undermine the Royal Park Wetlands, which supply water for Melbourne’s parks and street trees and for the Royal Park Golf, including the vast water storage tanks under the Ross Straw field. This will affect not only Royal Park itself but all the city parklands that rely on the water storage;
- destroy a Registered Geology Society of Australia railway cutting, created in 1850. In conjunction with the Royal Park Railway Station cutting, this is one of the traditional teaching sites for geology in Melbourne. The site displays palaeo-landsurfaces, weathering, fossils, an unconformity and a disconformity
The CIS fails to address the following issues in regard to cultural heritage:
- Proper assessment of impacts on the Melbourne cemetery and Royal Park-Secondary sources and aerial photographs do not constitute a sound basis for decision-making in relation to the cultural values of Melbourne General Cemetery and Royal Park; nor do they constitute a reliable basis for establishing the nature and extent of the physical risk to these cultural and heritage places.
- Adequate performance requirements. For example, ‘prepare archival record of buildings and streetscapes to be demolished’ is not of any use in mitigating the impact of demolition. ‘Develop archaeological management plan if site is affected’ and ‘rectify damage if it occurs’ are approaches that do not seek to prevent or even mitigate damage before it occurs. The CIS overrates both the availability and the likelihood of measures to mitigate the impact of the EWL on heritage and cultural issues. Even with recommended additional performance requirements, potential impacts can only be mitigated ‘to a greater or lesser degree’, while others cannot be mitigated at all. This should be concerning for the Committee.
- Sufficient consideration of impacts on “out of scope” areas of significance including the Zoo and ANZAC hall -Chapter 9 and Appendix G of the CIS, which are meant to address heritage and cultural impacts, note that the Melbourne Zoo is an individual site of heritage significance and is in Royal Park but outside the actual project boundary. Some of the Zoo’s history is provided. That is all. Possible impacts on the Zoo are not examined, presumably because it does not fall within the actual boundary of the project, even though it will be subject to years of being on the periphery of a construction zone and suffer directly post construction with elevated levels of traffic and disturbance. ANZAC hall will be within 200 metres of an open cut construction zone with heavy machinery yet is given cursory assurances that it is out of harm’s way.
- Complete assessment-1. Section 49A of the Aboriginal Heritage Act 2006 requires a cultural heritage management plan (CHMP) to be prepared if a comprehensive impact statement is required under the Major Transport Projects Facilitation Act 2009. Andrew Long and Associates is currently preparing a CHMP for the East West Link – Eastern Section. Until the CHMP is complete the CIS remains incomplete; until full consultation of the appropriate Aboriginal representatives has been completed and acted upon, the Committee is in no position to make recommendations;
- Independent assessment-2. There is apparent conflict of interest in the approvals process for other cultural heritage issues, as the Planning Minister has replaced the Executive Director and Heritage Victoria as decision-maker for his own projects;
The cultural heritage assessment was prepared for Government against Government Terms of Reference and based on Government information